LIBERI V TAITZ - EXHIBITS 1-22 TO Show Cause Response

Case 2:09-cv-01898-ER Document 106-2 Filed 08/26/2009 Page 1 of 7
EXHIBIT “1”
NOTE: This dossier #6 is posted on six (6) locations of Taitz website. Liberi’s SSN is
located on the last page.
http://www.orlytaitzesq.com/blog1/?p=8;
http://www.orlytaitzesq.com/blog1/?m=20090417;
http://orlytaitzesq.com/dossier-006.htm;
http://orlytaitzesq.com/drorlytaitzesq/documentation/Dossier6new2.doc;
http://www.orlytaitzesq.com/blog1/?cat=29; and
http://www.orlytaitzesq.com/blog1/?cat=3&paged=2
Dr. Orly Taitz Esquire

Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright
2009
« Dr. Orly Taitz Esquire

Videos on You Tube »
Dossier #6
Dossier #6
Dr. Orly Taitz, ESQ

26302 La Paz ste 211
Mission Viejo CA 92691
ph 949-683-5411
fax 949-586-2082
dr_taitz@yahoo.com
www.repubx.com
04.08.09.
Attorney General Eric Holder;

Solicitor General Elena Kagan;
Director of FBI Robert Mueller;
FBI Cyber Crime division, Orange County CA,
Officer Nathan Le
Director of Secret Service Mark Sullivan;
Chief of Security of the Supreme Court,
Officer Christine Giaccio;
Chief Justice of the Supreme Court John Roberts;
Legal Counsel to the Chairman of Joint
Chiefs of Staff Admiral Mullen, Captain Crawford
Via Certified mail, return receipt, restricted delivery addressee only

Dossier #6 in the form of

open letter posted on the internet and forwarded to 26,000 outlets of US and international media
Dossier #6 Further evidence of forgery; more questioned raised in regards to illegal
campaign contributions; efforts to undermine fundraising of dissidents, criminal element
used; more cyber crimes, defamation of character, identity theft; false leaders of the
dissident constitutional movement.
Please see in attachment affidavit of licensed private investigator Jorge Baro and forensic
document examiner Sandra Ramsey Lines. Both are stating that Certification of Live Birth
posted by Obama on internet cannot be viewed as genuine and original birth certificate from the
vault in Hawaii needs to be produced to verify his place of birth and citizenship.
Further you can see a statement by Suzie Murzinski in regards to fundraising by Obama in
Senegal, using Western Union. Fundraising abroad for the presidential election is illegal and this
statement is consistent with prior reports of Obama illegally getting campaign contributions from
abroad, mostly from Arabic Muslim countries.
Further you can see receipts showing diversion of campaign contributions. I have received e-
mails from donors, stating that they had problems with pay-pal. I described these problems in
dossier #5, specifically that the e-mail address in my blog for pay-pal was changed, which
prevented me from raising funds. My web master Lisa Ostella stated that such a report gives her,
as a web master. bad name and demanded that I take the hacking report back. She stated that she
was convinced that the changing of the e-mail address was done by a volunteer moderator Fran,
she stated that she locked Fran from the blog and that should solve the problem. I felt that the
matter needs to be investigated by the FBI and I felt that they should draw their own conclusions.
Ms. Ostella stated that if I do not take back my complaint to FBI, she will no longer host my
foundation on her server. When I found a new web master to host my foundation, Ms. Ostella
instead of transferring the access codes and the domain, has locked me and another volunteer
moderator out of the blog, posted a bizarre defamatory statement, that I supposedly authorized
hacking into my own account and further defamatory comments about me were placed under
different names and aliases. Moreover, there were comments posted supposedly under my name,
even though I was locked out of the account and couldn’t respond. I got reports that some
defamatory comments were made under alias usually used by Lisa Liberi, assistant for Attorney
Phillip Berg, who filed similar legal actions. I started receiving statements and copies of pay -pal
receipts, showing instead of my e-mail address, an e-mail address of Lisa Ostella. Originally, I
thought that maybe her address showed on the receipt, since she was a web master on the
account, however, when I checked the names and dates on the receipts against the names on the
roster, that I downloaded earlier, I could see that those were not received by the foundation,
those donations were missing.
A couple of weeks ago I have received a phone call, providing information that Lisa Liberi, a
paralegal, assisting Mr. Berg, has an extensive criminal record. I decided to verify that.
According to Mr. Neil Sankey, licensed private investigator with 20 years of experience in
Scotland Yard and over 12 years of experience in US, those statements were correct. Lisa Liberi
aka Lisa Richardson aka Lisa Courville and other aliases had an extensive criminal record going
back to 1990s, that included Grand Theft, forgery, forgery of seals “From 2000 to 2004, Liberi
engaged in a complex fraud involving falsification of police reports, manipulation of credit

bureau reports, loan fraud, and counterfeiting of court documents resulting in hundreds of
thousands of dollars in losses to banks and credit unions.” (see attachment). Please see the
report attached and reports relating to criminal conviction in San Bernardino California.
Interesting fact is that Lisa Liberi was convicted recently, in March of 2008, she was supposed to
serve 8 years in jail. Miraculously this 8 year jail term was reduced to probation and an order to
repay the victims. When I added up all the restitutions in the conviction, it added up to 21,000
per month. Where is this money coming from? Who is paying it? And paying to do what? I have
sent an e-mail to Philip Berg, alerting him to this matter, however I did not hear from him back.
After I raised my concerns to other parties and they confronted Liberi, she tried to claim that it is
not her, but another Liberi, that she lives in PA and the one convicted lives in NM, however
several sources confirmed that she indeed lives in NM, they confirmed her date of birth and
appearance as matching the ones on file with the San Bernardino, CA district attorney. I tried to
analyze the instances when Liberi was the most vicious in her attacks towards me and found two
distinct areas:
a. Obama’s Natural Born status and definition of it
b. my efforts to conduct investigation of illegal, criminal activity and my efforts to have FBI and
attorney generals of different states involved.
In regards to the Natural Born status, she claimed that she has written pleadings for Phil Berg
and that the citizenship of Obama’s father is of no importance. This was repeated time and again
when she appeared together with Phil Berg at different radio programs. In reality definition of
Natural Born citizen is, that it is one, who is born in the country, with both parents citizens of
the country, one that does not have allegiance to any other sovereignty at birth. It appears that it
was an effort to sway the public and redirect attention from the most obvious, the fact that
Obama’s father was not a citizen of the US and therefore he does not qualify, no matter where he
was born. Did someone help Liberi avoid 8 year jail term here in CA in exchange for her efforts
to cloud the issue?
Second issue dealt with criminal activities surrounding Obama and his supporters. I have been
the only one investigating those issues. Why?
Another interesting fact. Plains radio had a legal action against a blog radio talk show host
Evelyn Adams aka momma E. Momma E is represented in this action by attorney Philip Berg.
When Lisa Ostella locked me out of my own foundation, due to the fact that she has registered
the domain before I had an opportunity to do so; she created several diversionary blogs and
posted links to Momma E and a few other parties that are rumored to be plants, meaning false
leaders of the movement.
I am not a historian and not a theologist, however this whole situation reminds me of a story of
Shabtai Zvi. A few centuries ago there was a false leader in Europe, his name was Shabtai Zvi.
He claimed to be a Masaya and thousands followed him until he was summoned by a sultan, who
has given Zvi two choices:
First- if you are really a Masaya, you will be executed, but you will be resurrected as a Masaya.
Second - if you are not a Masaya and want to live, you have to convert to Islam.
Within about five minutes Shabtai Zvi put on a Muslim garb and converted and that was the end
of the false Masaya, false leader and false movement.
Similarly here, a leader is judged by his willingness to go all the way, regardless of hardships
and risks or financial problems. You can’t talk only about the birth certificate and not see an
elephant in the room, which is Obama’d British citizenship at birth, based on his father’s
citizenship. You can’t talk about his birth certificate only and not demand immediate
investigation of his numerous reported social security numbers, reported forgery of the Selective
Service Certificate, perjury on the Illinois Bar application, all the evidence of campaign
contributions fraud, charitable foundations fraud, tax fraud and numerous reports of his
supporters being engaged in cyber crimes, intimidation, harassment, identity theft and all the
other related crimes
Due to the above I renew my demand upon all the law enforcement agencies listed in this dossier
to conduct immediate criminal investigator, I demand on behalf of my clients Quo Warranto
proceedings to resolve those issues once and for all.
Sincerely,
Dr. Orly Taitz, ESQ
NOTE: EXHIBIT “A” REDACTED DUE TO LENGTH OF DOCUMENT
> From: nsankey@thesankeyfirm.com

> To: lisaostella@hotmail.com; dr_taitz@yahoo.com
> Subject: FW: >>>>>>>>>>Urgent IMPORTANT INFO SAME SUBJECT<<<<<
> Date: Mon, 16 Mar 2009 14:57:13 -0700
>
>
>
> PLEASE NOTE THE LAST LINE!
>
> Thursday, April 10, 2008
>
>
> New Mexico Woman Sentenced in Identity Theft and Real Estate Fraud
>
>
> Lisa Liberi, aka Lisa Richardson, 42, New Mexico, was sentenced in
> connection with felony charges involving identity theft and forged
> documents. Liberi appeared in San Bernardino County, Rancho Cucamonga,
> Superior Court, on March 21, 2008. She was sentenced to a state prison term
> of 8 years, imposed but stayed, and placed on supervised probation for 3
> years as part of a plea agreement. Liberi was sentenced on ten felony
> counts ranging from Grand Theft, Forgery, and Filing False Documents.
>
> From 2000 to 2004, Liberi engaged in a complex fraud involving falsification
> of police reports, manipulation of credit bureau reports, loan fraud, and
> counterfeiting of court documents resulting in hundreds of thousands of
> dollars in losses to banks and credit unions.
>
> In 2002, San Bernardino County Sheriff’s Department personnel arrested
> Liberi on theft by false pretense charges. In July 2004, Investigators from
> the San Bernardino County District Attorney’s Real Estate Fraud Unit
> arrested Liberi at the Ontario International Airport for additional felony
> charges while she was out on bail.
>
> She has an extensive criminal record going back to the 90’s.
From: Neil SANKEY <nsankey@thesankeyfirm.com>

Subject: FW: LISA LIBERI etc
To: dr_taitz@yahoo.com
Date: Monday, April 13, 2009, 7:04 PM
Here is the Liberi stuff you requested. This is also what I sent to Bob Unruh
From: Neil SANKEY [mailto:nsankey@thesankeyfirm.com]

Sent: Friday, April 10, 2009 10:01 AM
To: Bob Unruh
Subject: LISA LIBERI etc
Bob here are some bare facts about Berg’s assistant. See below and attachments
I don’t know how much of the story you have already, but is essentially about WHO she really is
and the questions that unfortunately brings up about Berg.
Call, if you need to, at your convenience.

Neil Sankey
Investigator & Consultant.
THE SANKEY FIRM
Simi Valley, California 93063

nsankey@thesankeyfirm.com
805 520 3151

818 212 7615 cell
(Addendum)
LISA RENEE LIBERI. Bn 5/28/1965. 462-45-xxxx, 622-19-4312 (& others)
According to the Police she was born COURVILLE and married a Richardson (Possible Alan
Douglas Richardson, currently residing in Las Vegas .) IF it was the other way around, then the
Courville is Bill Marshall Courville 11/10/61 of Houston , Tx. 457-71-x I have several SS#’s for
her and a LOT of AKA’s. Her real SS# is probably 462-45-xxxx. Most prominent otherwise are
563-60-xxxx, 572-17-x, 622-19-x She went BK in 2002 Her brother is probably Lawrence E
Morris of Fontana and Rancho Cuc , CA . He was born 1/16/64 Her Husband, Brent J, a Parolee,
I have not researched that. Is probably Brent J McCormack 563-77, also uses 331-02-x
There is also a Jerry HELLER and Douglas Cramer look interesting, but where do you stop?.
From: Neil SANKEY <nsankey@thesankeyfirm.com>

Subject: Bergs Paypal
To: dr_taitz@yahoo.com
Date: Monday, April 13, 2009, 7:15 PM
It comes as no surprise to learn that the link to a Visa donation to Berg, (as opposed to Paypal)
has been removed
Neil
This report came from volunteer Sarah redacted
NOTE: ATTACHED PRINT-OUT WAS REDACTED DUE TO LENGTH

EXHIBIT “3”
http://www.orlytaitzesq.com/blog1/?p=36

2009
« KY secretary of state
Million Patriots march »
Follow up on Lisa Liberi, paralegal to Phil Berg
In regards to Lisa Liberi, assistant to Phil Berg. As I stated, she has an extensive criminal record
of forgery, forgery of seal, grand theft and so on. Lisa Liberi was stating that it is not her, that it
is another Lisa Liber, and that she lives in PA and not NM, however this is not true. She lives in
NM, her home phone number and address is in NM and this can be verified with the probation
officer Joanne Martinez fax 505-476-2368, phone 505-827-8627.
I corresponded with John Hemenway ESQ, who filed Hollister v Soetoro case in DC for Phil
Berg and he stated that Lisa Liberi, who works for Berg lives in NM. When his son was buying a
truck in NM, she told him, that she lives there and can assist.
One of former volunteers for Phil Berg has written a statement and went with me to FBI in San
Antonio and reported that Lisa Liberi, who works for Berg lives in Santa Fe, NM and she sent
Christmas presents to Lisa to NM. Today many employees and volunteers work from home and
correspond via e-mails and phone calls. This volunteer stated that Lisa Liberi corresponds via e-
mails and phone. A person will not make a report with FBI and risk going to jail unless
she provides a truthful statement. She also recorded this statement on video.
I had three confirmations from 3 independent sources of the findings of licensed investigator Mr.
Sankey Before I posted dossier #6. After all the revelations the name of Lisa Liberi in Mr. Berg’s
site was changed to Agent88.
I believe, that when non-profit organizations are involved and donations are collected, one
should not employ people that are questionable and particularly people that have a lengthy
criminal record that includes forgery, forgery of seals and grand theft.
I have closed the pay pal account, when I saw that Lisa Ostella has redirected the the Defend
Our Freedoms blog and redirected the pay pal. Now there is no pay-pal for this foundation and
there will not be any more questions. I will be setting a direct visa/credit card donation button ,
where donations will go directly to the foundation, so there will not be a problem of someone
redirecting donations by changing the e-mail address on the pay pal button.
Yet another important matter. So far none of Obama eligibility matters have gone to trial and we
all are working hard to change it. But let’s say one such case goes to trial. We don’t want to be
impeached by Obama’s attorneys saying that we knowingly employed shady characters,
who might’ve supplied us with incorrect information. Just like the country needs to be purged of
Obama and his clique, that are in power by virtue of forgery, fraud and consealment of vital
records, the patriots of this country need to purge their ranks.
This entry was posted on Saturday, April 18th, 2009 at 2:29 pm and is filed under Other Criminal or Suspicious
Activities. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are
currently closed.
EXHIBIT “4”

2009
« Key witness in presidential passport case fatally shot

from Field McConnell »
Every day I get such evidence of missing or misdirected funds

Every day I get such receipts, showing that my former web master Lisa Ostella (posts under name
Calpernia) has redirected donations to herself, to her e-mail address. Currently, as this was uncovered,
she created new web sites Defend our freedoms .org, .net and continues the scheme by making those
sites similar to my old ones and using the foundation name to steal more donations. She created a visa
donation site with her e-mail account Go Excell Global, underneath she posted a paypal button showing
my foundation Defend Our Freedoms (without my consent) and my e-mail address (without my
consent) to look as if she is still connected to me and my foundation, even though all ties with her were
severed a couple of weeks ago, when I found out about this scheme and I closed the Pay Pal account
completely. Any person, whose donations were stolen by Lisa Ostella aka Lisa Current aka Calpernia is
asked to report this to his local police or sheriff’s department. As I found out, she appears to be
connected to Lisa Liberi, who is still working for attorney Phillip Berg. Please see my dossier #6, Lisa
Liberi aka Lisa Richardson aka Lisa Courvelle has a long criminal record, that includes grand theft,
forgery of documents, forgery of seal, falsification of police reports and credit statements, where financial
institutions were defrauded out of thousands of dollars. She claims to be a different Lisa Liberi, living in
PA, however she lives in NM and her probation officers are Joanne Martinez 505-827-8627 and Dawn
Helling (not sure about spelling) 505-476-2359.
Hi Dr. Taitz,
Just to let you know that I donated to your cause on 1/19/09 thru PAYPAL. I copied the transaction that
was provided to me by PAYPAL, please see the following:
Dear Joseph Iadarola,
This email confirms that you have donated $25.00 USD to Defend Our Freedoms
(lisaostella@hotmail.com) using PayPal.
Donation Details
Confirmation number: 0MT49606HT922673B

Donation amount: $25.00 USD
Total: $25.00 USD
Purpose: For being a great American!
Contributor: Joseph Iadarola
Recipient information
Donations coordinator: Defend Our Freedoms

Contact email: lisaostella@hotmail.com
Contact Phone Number: 866-954-5625
This entry was posted on Sunday, April 19th, 2009 at 8:32 am and is filed under Other Criminal or Suspicious
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EXHIBIT “5”

2009
« Supporting Documents, Downloads.

Upcoming appearances »
Update on Lisa Ostella and Lisa Liberi

TUE APR 21st
Dear Dr. Taitz;
I have been following your activities to force Barack Obama to comply with the
requirements of our Constitution, but was floored this morning when I read what
the Webmaster Ms. Ostella had done to you.
This is so obviously a crime. You should ask law enforcement to bring criminal
charges for stealing you good name and donations intended exclusively for you.
You in turn should file a civil suit suing her for theft and ask for large punitive
damages. You certainly have proof of damages if what you wrote is true and it
sounds plausible. Please keep up your work. God bless America!
Good luck,
Al Barrs
albarrs@wfeca.net
Greenwood, FL
Dear Mr. Barrs,
I have reported the matter to the Sheriff’s department and FBI . See below the
receipt for the police report with the name and phone number of the detective.
The name of the FBI agent is John Haas- supervisor of the cyber crimes unit 714-
542-8825. Please spread the word and give everybody the new web address for
the Defend Our Freedoms Foundation, which is http://www.OrlyTaitzEsq.com
Please post this web address in as many blogs and sites as you can, so it will be
picked up quickly by different search engines and can be seen by all my readers. I
have closed my pay pal account and did not receive any pay pal or visa donation
since 04.11.09. If you or anybody else has given any donations after this
date, using pay-pal, visa, MasterCard, American Express and so on, believing
that these donations were received by the Defend Our Freedoms foundation,
please demand a refund and report it to the Sheriffs department, FBI and IRS as
funds stolen from the non profit organization. I have sent a Cease and Desist
letter to Ms. Lisa Ostella, demanding that she forward to me the access codes for
the domains and the e-mail address list of the readers and stop fraudulently
operating under the name DefendOurFreedoms and stop drawing financial profit
from the Defend Our Freedoms name. I have also sent a Cease and Desist letter
to Evelyn Adams aka Momma E, talk show host David Levin and other parties
who are fraudulently advertising on the foundation website and drawing profit
from it or from reader lists given or sold to them by Ms. Ostella. Ironically Ms.
Ostella has accused me of collecting information on the readers. In reality I did
not have any such information and could not reach most of the readers, aside
from ones whose names were in my dr_taitz@yahoo.com e-mail account. Ms.
Lisa Ostella is the one, who collected names and e-mail addresses and she is
currently fraudulently sending e-mails to these readers using
DefendOurFreedoms name. If you get such e-mail, please demand that she
immediately stop this practice and forward the list to me, as the president of the
foundation.
My primary goal is to expose all the fraud committed by Obama and removing
him out of office as an usurper, litigation against Ms. Ostella is secondary. I also
need to get full information in regards to full damage to the foundation and me,
stemming from actions of Ms. Ostella and parties that patronage her site and
are aiding and abetting her.
I, also, sent an e-mail with dossier #6 to Mr. Phil Berg, advising him of lengthy
criminal record of grand theft, forgery, forgery of seal and other related crimes,
committed by Ms. Lisa Liberi, his paralegal and assistant, who reportedly was
managing his fund raising efforts. I believe Mr. Berg should not be using a
person with such past in his fund raising efforts and legal practice and should
issue a statement advising the donors and supporters, that Ms. Lisa Liberi is no
longer employed by him or his foundation and that he is reviewing all donations
and all legal records handled by Ms. Lisa Liberi. I believe the donors to Mr.
Berg foundation should get assurances that their donations were used for
litigation and the cause and not to reimburse victims of Ms. Liberi’s prior
schemes, reported to add to $21,000 per month.
Sincerely,
Dr. Orly Taitz, ESQ
04.21.09.
Tags: Add new tag, Berg litigation, birth certificate, crimes Lisa Ostella, Lisa Liberi, obama
This entry was posted on Tuesday, April 21st, 2009 at 8:29 am and is filed under HOT ITEMS!, LINKS, Legal
Actions, Letters from Readers and Patriots, Other Criminal or Suspicious Activities, Supporting Documentation.
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EXHIBIT “6”

2009
« Updates on radio shows; Interview at 6:30 PM PDT on No Compromise Radio

From a reader, can someone do it? »
More attacks on me. More indepth research is done in spite of attacks

Recently I got an e-mail advising me on more attacks on me and my family, claiming that I and
my husband spy on people,. What nonsense. Anybody is welcome to check my programs. The
software used is Wordpress, that is used in most blogs, my husband has nothing to do with my
work and all the allegations are without any proof. On the other hand, each and every thing I
publish is backed by evidence. For example: when I reported that Obama’s certification of live
birth has signs of forgery, I presented a statement from a forensic document expert. When I
stated that Lisa Liberi, paralegal for Phil Berg has a lengthy criminal record, I provided the
printout from the DA and private investigator, showing a lengthy record of grand theft,
forgery, forgery of seal and other similar crimes (attachments in dossier #6). These people are
simply attacking me and my family, because I am successful in uncovering illegal and criminal
activities, they get scared and are trying to scare people into not reading this damaging
information that I uncover, they don’t want the public to know the truth.
I am preparing dossier #7 and I need help in research in the following areas:
1. any and all newspaper articles about Baxter pharmaceuticals flu vaccines, infected with live
strain
2. any info on campaign contributions from Baxter to Obama
3. how did Baxter become the company associated to WHO, responsible for coming up with
swine flu vaccine?
4. who are the major shareholders of Baxter?
5 which companies manufacture Tamiflu and similar medications, their contributions to Obama,
their shareholders?
6. who is responsible for entering data at Intelius Jobs.com and removing such data, how is it
done?
7. what investigation was done at 29th palms marine base re the swine flu?
8. were there any other recent suspicious flu outbreaks at military bases?
This entry was posted on Friday, May 1st, 2009 at 10:11 am and is filed under Health & Safety, Help Needed. You
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EXHIBIT “7”

2009
« Proposed quo warranto, to be delivered to Atty. Gen of GA

Visiting the Center for Disease Control and other agencies in Atlanta GA »
Check public records for yourselves, see that I am providing truthful

information
I would like to respond in regards to some allegations that came forward recently.
As you can see in dossier #6 on this blog, I have received verified information from a licenced
CA Private Investigator Mr. Neil Sankey (license 10905) , that Lisa Liberi, working as a
paralegal for Phil Berg has a lengthy criminal record of grand theft and forgery (see dossier #6).
I have sent Mr. Berg this information, he never responded and never denied it. Due to the fact
that Ms. Liberi has access to numerous documents and donations, I was obligated to provide this
information to the public. Information that was provided, is public record and I urge everybody
to call San Bernardino, CA criminal court system as well as NM probation officer (number in
dossier) and verify that all the information is correct. I have urged Mr. Berg to disassociated
himself and his practice and donation efforts from this person and hire a forensic accountant and
forensic document examiner to review all documents and forensic records handled by her. Mr.
Berg did not do so. From what I understand their website was under lockdown and Ms. Liberi
went by name Agent88.
Paperwork filed yesterday was nothing but slander against me, a lot of sand in the eyes, but if
you read carefully, the only thing they are trying to do, is further hide Liberi’s identity, saying
that there is an undisclosed address and asking for a new social security number. They do not and
cannot deny following important points:
1. Lisa Liberi, working for Philip Berg, resides in New Mexico, previously resided in CA and
has a lengthy record of grand theft and forgery of documents.
2. Phil Berg was warned by me and a volunteer, that her continuing association with the Obama
litigation undermines everybody’s work and everybody’s effords, as it puts into question
integrity of fundraising of donations and veracity of any and all documents handled by her.
3. Regardless of what might be financial and other arrangements of Mr. Berg with Ms. Liberi, as
an officer of the court, he had a duty to disassociate his fundraising efforts and legal research
from her. I believe he owes this to all the patriots involved in this effort, particularly people like
me working 24/7. He has an obligation to hire a forensic accountant and forensic document
examiner and check all the records. Imagine, if any of Obama eligibility cases go to trial, Berg
and any and all attorneys will be impeached and reasonable doubt will be in the minds of the
jurors, if they know that the documents presented, were gathered by a person with the record of
forged documents, that the supervising attorney knew about it and made no effort to disasiociate
himself and verify the records by the licensed professional. Rest assured, that if I could obtain
this information about Ms. Liberi, so could Obama’s attorneys, with millions of dollars available
to them. I am wondering if Ms. Liberi’s association with Mr. Berg was mastermind by
somebody, as she had a conviction in March of last year, was supposed to serve 8 years in San
Bernardino CA, but the sentence was reduced to probation and restitution to victims.
4. On the contrary, as the first donors reported to me problems with pay-pal, I have reported this
to the police and FBI immediately. The reports were posted on the blog. When web master Lisa
Ostella has stated that she wants me to take back my complaint, I switched to a different web
master and made sure that with the current web master my e-mail address is listed on the
registration of the domain, in order not to have the same problem. Ms. Ostella’s actions as a web
master in locking me out of my web site, allowing several days of defamatory statements and
later defrauding the donors and my foundation, by sending e-mails and claiming to represent
foundation and soliciting donations for the foundation are inexcusable and will have to be
prosecuted in due time.
5. I did not intent to prosecute this matter at this time, as I felt that Obama eligibility prosecution
and research is more important for the country at large, however I will respond as required to the
filing by Mr. Berg.
6. I wonder in regards to timing of this complaint, as I am making progress in a number of states

and with a number of plaintiffs. If Mr. Berg is really concerned about this country and it’s
future, he should dismiss this outrageous and frivolous complaint immediately, disassociate
himself from both Ms Ostella and Ms. Liberi and not waste my time, that is needed to organize
more citizen grand juries, more meetings with attorney generals of the states, local FBI offices,
US attorneys, grown numbers in resistance movement and turn this country around. All of the
stonewalling that we have observed, indicates that the problem is much bigger, then birth
certificate. I am the only attorney, who has the courage to bring to the forefront all of the
evidence of forgery,perjury, multiple social security numbers, unreported job positions. Judges
are hesitant to decide based on birth certificate only. it is extremely important to push for
criminal investigation of all the issues. This frivolous law suit simply wastes my time and
resources.
Dr. Orly Taitz Esq.
This entry was posted on Tuesday, May 5th, 2009 at 7:57 pm and is filed under Uncategorized. You can follow any
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EXHIBIT “8”
http://216.221.102.26/blogger/post/Follow-up-on-the-FBI.aspx
Follow up on the FBI

by orlytaitz April 17, 2009 12:22
I just got of the phone with Mike Haas- supervisor of the Cyber Crimes unit with the Orange
County, CA FBI. He is my point of contact, phone 714-542-8825. He will give the case to the
supervisor of the forgery unit and will get back with me later on today or on Monday.
I need everybody who donated to my foundation and have seen change of the e-mail address,
where instead of my e-mail (orly.taitz@gmail.com or dr_taitz@yahoo.com) to contact the
superviser of the cyber crimes unit 714-542-8825 and report this.
I got an e-mail a while ago, that a gentleman was selling a motorcycle and stated that he would
donate the proceeds to my foundation. I was told that there was bidding as high as 7,500, but I
never got that donation. If you are a person that was selling that bike or you are a person that
bought that bike, please contact me 949-683 -5411.
I received information that Lisa Liberi and her husband had an access to the credit card donations
for Phil Berg. If you have any info on this, please contact me.
If you know of any defamatory or fraudulent statements, any evidence of cyber crimes, fraud,
identity theft made after Lisa Ostella has hijacked my foundation blog, please forward this to the
above number. If you have evidence of any other federal crimes committed in relation to my
case and Obama eligibility case, that I am investigating, please forward it to the same point of
contact, same number.
EXHIBIT “9”
http://216.221.102.26/blogger/post/More-on-Lisa-Liberi-contact-her-probation-officer-in-Santa-
Fe-New-Mexico-505-827-8627-She-is-not-allowed-to-be-anywhere-near-other-peoples-credit-
cards.aspx
More on Lisa Liberi, contact her probation officer in Santa Fe

New Mexico 505-827-8627. She is not allowed to be anywhere
near other people's credit cards
by orlytaitz April 17, 2009 11:01
EXHIBIT “10”

2009
« Update in re to SCOTUS
from reader Penni Basse »
I need two articles and update on Lisa Liberi

First of all, I got a number of questions in re to Lisa Liberi, as through some surrogates
Lisa Liberi was spreading rumors that she is an innocent Lisa Liberi, residing in PA and the one,
I’ve written about is a different Lisa Liberi, residing in New Mexico.
Well, in the pleadings prepared by her and Berg and in their joint radio appearance on the redio
of Momma E aka Evelyn Adams, they admitted that I provided correct and truthful information,
as Liberi stated that after I provided her address, she became fearful of her ex-husband and now
she needs to go into hiding and change her social security number. The only information I
provided, is one of Lisa Liberi, residing in NM. If she would’ve been this woman residing in
PA, she would’ve had no reason to be concerned about me providing an address in NM.
She does reside in NM, she corresponds with Berg via e-mails and phone and Berg needs to
explain to the public and donors, what is his justification for continuing employment of one with
such a serious criminal record of forgery and grand theft.
Initial evidence in Obama eligibility case became a public record in August of 2008. I am not
using a record of affidavits, that they presented, but I would like to confirm this school
registration, that originally was published in a newspaper in Indonesia. Can someone find it?
I am, also, looking for the newspaper article, that has a full press conference with Janet Okubo,
spokesperson for the Director of Health of HI Dr. Chiyome Fukino. Can anyone find this full
press conference?
This entry was posted on Friday, May 8th, 2009 at 12:28 pm and is filed under Dossiers. You can follow any
EXHIBIT “11”

2009
« from another attorneys

Media Blitz »
Information update on both Liberi and Obama

Submitted on 2009/05/09 at 5:09am
His last postings on his site:
THE LATEST
01/02/2009: PRESS RELEASE - Philip J. Berg, Esquire Obtained the Obama 1964
Divorce File
01/02/09: BERG files a lawsuit on behalf of a RETIRED COLONEL The lawsuit is an

“Interpleader” that shifts the burden of proof to OBAMA Further, OBAMA is named as
“BARRY SOETORO” as that is his “real” name when he was legally adopted in Indonesia
01/02/09: The latest in the Berg vs. Obama Case No. 08 - 570 is that there are two
conferences scheduled; one for January 9, 2009 to hear the Petition for Writ of Certiorari
and the other for January 16, 2009 to hear the Petition for Injunction.
I got this information. Beginning of January was the last time there was any info posted on
Berg’s site.
By the way, Berg and Lisa Liberi got Dunham-Soetoro divorce papers from me and they got
Dunham-Obama divorce papers from Ed Hale.
Prior to the electoral vote I tried to file a legal action on behalf of the electors, to get verification
of Obama’s eligibility. I got in touch with some attorneys in Conservative red states and asked
them to file with me and sign Pro Hac Vice- it is a form that allows an out of state attorney to
work together with the in state attorney. I Worked with an attorney in AL, Keith Cornett and
later Ben Dupre, associate of Moral law center, that is ran by former Chief Justice of Al Supreme
Court Rory Moore. I studied all of Al elections statutes and Keith Cornett filed a request in HI to
get Dunham divorce papers. When he couldn’t get them, I got in touch with attorney Jim
Hochberg in HI and he personally went to the court house and got the Dunham -Soetoro papers. I
e-mailed Berg and stated that I got these divorce papers and would like to know if they want
them, since it can help both cases. Berg asked me to e-mail them and later Lisa Liberi called and
asked to mail a hard copy.
Dunham-Obama divorce papers were obtained by Ed Hale, who paid a private investigator to go
to HI and obtain the copy.
I never asked for any credit. Many of you read my blog and you could see that I didn’t even
mention hundreds and hundreds of hours I’ve spent trying to bring an action on behalf of
electors, who would have a better standing. At the end we could not file such action in AL, since
the statutes were amorphous, it wasn’t a strong hook, however Mr. Robert Cusanelli, an elector
from AL, who actually voted in the 2008 electoral college, became one of my plaintiffs. Now
you know how much work was done in conjunction with this one plaintiff, one out of over a
100.
Considering all the work that I have done, the allegations coming from Berg, are just outrageous
and hurtful. I believe a lot of what Berg is doing now is related to some criminal issues involving
Lisa Liberi. I got information from one of the people that worked with Berg and Lisa Liberi,
whereby Lisa Liberi stated that she gets disability payments from social security and those
payments were paid by Berg to her husband, so that she can continue receiving disability
payments. I decided to check this matter and called James Secord-District Attorney of San
Bernardino county in CA, who prosecuted Lisa Liberi, when she got 8 years in jail for grand
theft and forgery and this jail term was stayed and reduced to probation and restitution,
supposedly because of her medical disability. Mr. Secord has confirmed all of the information
in regards to her conviction and stated that she is indeed getting disability payments from the
government. If Berg is paying her for her services and it is done in any form: check or cash or
indirectly through her husband, it is a very serious offense for both of them. I would like to find
as much information, as I possibly can in regards to this matter. If you have donated to Berg,
where did the donation go? I believe, Berg filed this frivolous action to keep everybody quiet
about Lisa Liberi’s past and her current actions. Another matter, that I am trying to ascertain,
where does she get the restitution that she owes to the victims of her felonious activities in CA. If
you read dossier #6, you can see that the total restitution is $21,000 per month. Possibly it was
reduced to 12,000 per month. Where is this money coming from? If she is on disability and her
husband is working at a factory, where do they get this kind of money? This is a catch 22. If she
is not paying restitution, she is supposed to go back to jail and serve her 8 year term. If she is
paying this restitution and she is paid by Berg, then there are two very serious problems:
a. she is working with donations and other people’s credit cards, which means she is violating
her probation and supposed to go back to jail. Berg should not be allowing her to be anywhere
near the donations
b. If she is getting any payments from Berg, while getting disability, that is fraud and she is
supposed to go back to jail and is supposed to be prosecuted on these additional charges.
Her probation officer is Dawn Hellwig. Another officer in the department, who is familiar with
the case is Johanne Martinez. If you have given any donations to the offices of Phil Berg, you
need to contact Dawn Hellwig and demand an answer. I need to know if there are any
volunteers, who live in Santa Fe.
There is another issue. Did somebody arrange for her to be associated with Berg, to get him into
serious legal trouble. Was this arranged to begin with? I discovered an interesting detail and
need your help in getting to the bottom of this.
Liberi was first arrested in Rancho Cucomanga Ca, being involved in financial fraud schemes
going back to 2001-20o2. When I looked at the name of the town, I remembered, that among
130 jobs for Barack Obama and Michelle Obama, there was one notation: Michelle Obama
working for “Muslim World Today” in Rancho Cucomanga, CA. (dossier #1)
I remember being surprised,since Obamas claim to be Christian. As I’ve written in dossier #7,
this current position was recently erased with 110 other positions and I demanded investigation
in this destruction of evidence affair. Of Course Holder did nothing so far.
Another parallel. According to District attorney Secord, Liberi has changed her social security
number several times and now she applied for yet another SS number.
If you recall in dossier #1, I provided 100 addresses around the country for Obama that are
connected to 25 different social security numbers.
Liberi has changed her last name. Her name was Corvelle and Richardson. For some reason she
and her husband suddenly took the name Liberi. According to the private investigator, the
husband’s last name was Brent McCormick.
By the way, her social security number is a public knowledge, not only because of her conviction
for grand theft and forgery, but also because of her bankruptcies. According to the private
investigator, Mr. Sankey, there are 4 bankruptcy filings done by her: one -under Richardson, one
under Corvelle and two under Liberi. This information is readily available to 5 billion people on
the planet, who have access to Internet, which makes Berg’s case for injunction totally frivolous.
I need all the information, that can be found in regards to criminal convictions for her and her
husband. I need to know all of their associations, particularly in Rancho Cucomanga CA.
There are Internet services, that can give you a printout of web sites, as they were a month ago
or a year ago. These are crawlers, that scan the Internet. One of them is “Internet Access
Wayback Machine”. There are other similar services. I need your help in getting info in both
directions:
a. all of the names, addresses, social, associates, convictions, incarcerations for Liberi. Any and
all info on her husband. You can see past recordings on the Wayback machine.
b. any and all info on those 100 addresses and 25 social security numbers for Obama and 130 job
positions for Obamas . When did those appear in databases and when were those erased? Those
addresses and ss numbers and job positions came from Lexis-Nexis, Choice Point, Jobs.com
Intellius.
I was asked, How do they get those addresses? It is all coming from public records: non-profit
organizations, their donations records, county recordings, real estate recordings, probate records
of the deceased (do you remember that Madeline Dunham, Obama’s grandmother was a
volunteer for the probate department of Oahu circuit court), disclosed salaries (if you recall,
recently Washington DC FBI has raided offices of Vivek Kundra, Obama’s chief of computer
security and arrested his assistant amidst allegations of creating bogus job positions and splitting
salaries). We need to find the connections: who and when created those fraudulent units and who
and when erased them.
I need help from patriots, who are in law inforcement, such as Police, Sheriff, FBI, Marshall, DA
, Border Patrol, military police. Most importantly in CA, NM, PA, Il and DC.
Tags: Berg litigation, birth certificate, eligibility, natural born citizen, obama, orly, taitz
This entry was posted on Saturday, May 9th, 2009 at 9:22 am and is filed under Dossiers, HOT ITEMS!, Latest
News, Uncategorized. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and
pings are currently closed.
EXHIBIT “12”

2009
« Obama is running a horrific 1.8 trillion dollar deficit this year, leading this country straight into
bankruptcy
Follow up on Muslim World Today »
Update on Obama investigation and Liberi investigation
Case Number Results In Same
New Window
Defendant 1 of 1
Case FSB044914 Defendant 1608112 LIBERI, LISA
Arrest Charges
Violation
Count Charge Severity Description Plea Status
Date
PC OFFER/ETC FALSE/FORGED INSTRUMENT

1 F 11/15/2002
115(A) TO FILE
Filed Charges
Violation
Date

1 F 11/15/2002 HTA
115(A) TO FILE
PC
2 F FORGERY 11/15/2002 HTA
470(D)
PC
3 F FORGERY 11/15/2002 HTA
470(D)
4 PC 472 F FORGE OFFICIAL SEAL 11/15/2002 HTA
Infor Charges
Violation
Date

1 F 11/15/2002 ACTIVE
115(A) TO FILE
PC
2 F FORGERY 11/15/2002 ACTIVE
470(D)
PC
3 F FORGERY 11/15/2002 ACTIVE
470(D)
4 PC 472 F FORGE OFFICIAL SEAL 11/15/2002 ACTIVE
Home
Name Search Results
Party Name Type Case Name Category Case Number Filed

PFF BANK & TRUST - Complaint for
LIBERI, LISA R DEFENDANT RCIRS057001 08/14/2001
V- LISA R LIBERI Money (ltd)
BUSINESS BANK -V- Breach of
LIBERI, LISA R DEFENDANT RCVRS059008 11/06/2001
LISA R LIBERI ETAL Contract
NATIONAL CREDIT
LIBERI, LISA R DEFENDANT ACCEPTANCE-V- Collections (ltd) RCIRS083719 10/27/2004
LISA R LIBERI
LIBERI, LISA LISA R. LIBERI -N- DISSOLUTION
PETITIONER RFLRS031189 09/13/2001
RICHARDSON BRENT J. LIBERI OF MARRIAGE
LIBERI-V-COUNTY
LIBERI, LISA Civil Rights -
PLAINTIFF OF SAN SCVSS98957 01/14/2003
RICHARDSON Discrimination
BERNARDINO
LIBERI-V-J RIVAS ET
LIBERI, LISA PLAINTIFF Quiet Title SCVSS107057 08/25/2003
AL
REDLANDS
Other Civil
LIBERI, LISA DEFENDANT CENTENNIAL BANK SCISS78115 06/05/2001
Contracts
VS. LISA LIBERI
In regards to Obamas, if you recall, they had some 100 addresses in National databases, he had
25 Social security numbers and they both had 130 job positions. Recently most of this info was
erased from National databases, but we have a hard copy in Dossier#1.
One of the job descriptions was for Michelle Obama- with a newspaper “Muslim World Today”
in Rancho Cucomanga, CA. I called the directory, there is no listing for this News Paper. They
do have a large Muslim Community and a Muslim American Society. I tried to call them and
inquire about the News Paper. The Phone number 909-945-5078 is currently disconnected. Do
we have volunteers in that area?
In regards to Liberi she also has several social security numbers and several names. From around
2000 she lived in this small community of Rancho Cucomanga and it looks like she changed her
name around that time. Aside from 8 year prison term, that she got last year, that was reduced to
probation(how and why?) she has another active case, see above, where the charges include
forgery and forgery of seal. She might be looking at additional prison term on those charges, if
convicted at trial. Talking to the arresting officer and DA, I found out, that this woman sues
everybody around her. She makes up charges and slanders people, hoping to intimidate and
harass them and reduce her prison term. You can see among the charges one, where she filed
against the county. I can understand, why she is coming up with all those slanderous charges
against me and everybody around, she wants people quiet, but it is sad that Berg, an attorney, fell
into a trap of a common criminal. I don’t get harassed, I don’t get intimidated, she cannot pull
this garbage with me and I will get to the bottom of it. It seems to me that this woman was
somehow planted to discredit Berg and the whole Obama’s illegibility for presidency litigation.
We don’t need tainted evidence coming from her, we will win without any evidence prepared by
her. There is sufficient evidence against Obama without her. I believe she is a diversion and was
put in place to discredit the effort. I believe Phil Berg needs to distance himself from her, and
cooperate in getting to the bottom of this matter before this issue becomes irreversible for him.
This entry was posted on Monday, May 11th, 2009 at 2:59 pm and is filed under Uncategorized. You can follow any
EXHIBIT “13”
**Note: Scroll past the Name list and you will see Taitz writings about Liberi.

2009
« need PA Fed court attorney

Go NY »
I need to get more answers

Please, look at these records again
Name - DUNHAM, STANLEY ANN
Gender - Male
Street Address - 1617 S BERETANIA ST APT 1008
City, State, Zip - HONOLULU HI 96826-1112
Probable Current Address - No
Telephone -
Telephone Accountholder -
Social Security - 535-40-xxxx
Age - 52
Date of Birth - Nov 29, 1942
Deceased - Yes
Date Record Verified - Mar 87 - Dec 08
*********************************************************************************************************
Name - SUTORO, STA

Gender - Male
Street Address - 1617 S BERETANIA ST APT 1008
Telephone -
Age - 67
Date of Birth - 1942
Deceased - No
Date Record Verified - Mar 87 - Aug 07
******************************************************************************
***************************
Name - DUNHAM, STANLEY A

Gender - Male
Street Address -
City, State, Zip - 96826

Telephone -
Age - 52
Deceased - Yes
Date Record Verified - Nov 95
******************************************************************************
***************************

Gender - Male
Street Address - C O MADELYN DUNHAM
City, State, Zip - HONOLULU HI 96826
Telephone -
Age - 52
Deceased - Yes
Date Record Verified - Oct 95
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - C O MADELYN DUNHAM
Telephone -
Age - 67
Deceased - No
Date Record Verified - Oct 95
******************************************************************************
***************************

Gender - Male
Street Address - 8 WEST ST APT 4
City, State, Zip - NEW YORK NY 10004-1001
Telephone -
Age - 52
Deceased - Yes
Date Record Verified - Oct 94 - Jan 95
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - 8 WEST ST APT 4
Telephone -
Age - 67
Deceased - No
Date Record Verified - Oct 94 - Jan 95
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - 235 E 40TH ST
Telephone -
Age - 67
Deceased - No
Date Record Verified - Apr 93
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - 1512 SPRECKELS ST STE E402
Telephone -
Age -
Date of Birth -
Deceased - No
Date Record Verified - Dec 92
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - 1512 S
Telephone -
Age -
Date of Birth -
Deceased - No
Date Record Verified - Jan 90 - Dec 91
******************************************************************************
***************************

Gender - Male
Street Address - 1512 SPRECKELS ST APT 402
Telephone -
Age - 52
Deceased - Yes
Date Record Verified - Jan 87
******************************************************************************
***************************

Gender - Male
Street Address - 235 E 40TH ST APT 8F
Telephone -

Age - 52
Deceased - Yes
Date Record Verified -
******************************************************************************
***************************
Name - ALBRIKTSEN, PHYLISS

Gender - Female
Street Address - 4424 156TH ST SE
City, State, Zip - BOTHELL WA 98012-4718
Telephone - 425-485-8815 - PST
Age -
Date of Birth -
Deceased - No
Date Record Verified –
As you can see somebody used this record of Obama’s mother, Stanley Ann Dunham, in
different fashion. There were records created for her as a female and as a male. Noteworthy is a
fact, that in 1987 she is marked as deceased, and in 1990, three years later, she is alive again.
Now look at this record with the social security number belonging to Stanley Ann Dunham and a
name of Phyliss Albriktsen. Who created this record and why? It has to be somebody, who knew
Dunham’s social and the name of her classmate from WA, Phyliss Albriktsen, who was only a
couple of months older then Dunham. I don’t think Phyliss created this record. Typically people
don’t know the social security numbers of their friends. Could it be Dunham herself? Could it be
“somebody” who was close to Dunham, knew her ss number and probably has seen Phyliss
Albriktsen’s name somewhere in an old year book?
Now look at Obama- see in Dossier #1- 100 addresses with 25 different ss numbers.
Now look at this Lisa Liberi, who prepared the records and the case for Phil Berg. I believe some
of those records were leading into a dead alley and association with her would ‘ve compromised
the case to the point of no return, specifically because of her history of forgery. Was she used to
compromise the whole effort? What is her history? Numerous convictions of grand theft
and forgery. Just like with Obama , her records show numerous social security numbers. I am
trying to ascertain where did she live before CA- all the states, addresses and ss numbers. When
exactly did she change her name to Liberi from Courville or Richardson? When did her husband
or ex-husband Brent change his name to Liberi? She claims to live in PA, but says that I invaded
her privacy by providing her address. The only address I provided was one in NM. How would it
harm a person in PA if an address of somebody in NM was disclosed? What is her real social
security number? Why did she apply for a new ss number in CA in 2000? Did she try to cover up
a prior criminal record? Just a year after she got this ss number in CA (not in PA) she was
arrested on economic crimes in Rancho Cucomanga, CA. For some of these crimes she got 8
year prison term in CA, that was reduced to probation, some are still pending trial. When did Phil
Berg find out about this record? Why did he continue employing her? Why does he still employ
her? Is he being threatened by her or somebody else? Is this a threat of disclosure of facts? What
facts? From what I understand, Momma E aka Evelyn Adams and her husband JD Adams lived
in CA too. Was there any connection between them and Liberi? Did they reside in PA or NJ? Do
they have any record? We really need to get to the bottom of all of this. We don’t want any
surprises in court. We need to know it all before it goes to trial.
This entry was posted on Wednesday, May 13th, 2009 at 7:41 am and is filed under HOT ITEMS!, Help Needed.
You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
EXHIBIT “14”

2009
« Previous Post
Political Question Doctrine »
Please write to your congressmen and senators

Submitted on 2009/05/16 at 12:28am
On the news last night a man received a stimulus check for his mother, he told the reporter
that she died in 1967.
The Social Security Administration doesn’t seem to be very worried about it.
I haven’t worked in several years but I don’t qualify for a stimulus check because I didn’t
have income of at least $3,000. last year or the year before.
Please write to the Social Securtiy Administration. This is a real scheme. They need to clean the
records of the social security numbers of the deceased or people having numerous numbers. We
have seen Obama with numerous SS numbers, we have seen Lisa Liberi with numerous ss
numbers. These schemes brake the back of our economy. Demand from your state and US
representatives and senators to clean up SSA schemes, immediate audit of ss rolls, purging of all
ss numbers of the deceased or multiple numbers and vigorous prosecution for the ss fraud and
identity theft. Keep in mind that even theft of the ss number of the deceased is an identity theft
This entry was posted on Saturday, May 16th, 2009 at 5:47 am and is filed under Uncategorized. You can follow
any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
EXHIBIT “15”

2009
« Who owns the land allocated for the North American Union Superhighway?
From reader Ted on disaster economy »
Voter verification
this is important. look at the link. It shows the states that require paper trail of the electronic
voting.
We need to do a couple of things.
1. Lets check those 100 addresses with 25 social security numbers for Obama, how did they
vote? What I mean: Did they vote? What residences on file?
2. We need to start checking from OH- swing state and SOS Jennifer Brunner was completely
out of control, she was allowing people to vote with the address of park in the bench. Buss loads
of people were coming from out of state, how many of them were bench in the park inhabitants?
3. I was curious about those several ss numbers of Lisa Liberi, any voting? In any states?
Flag this message
Voting issues
Wednesday, May 20, 2009 2:12 AM
From:
“Magnus Johansson”
To:
dr_taitz@yahoo.com
Orly!
Can this site http://www.verifiedvoting.org/index.php be of any help in your investigation

concerning voting fraud?
Regards,
Magnus
This entry was posted on Wednesday, May 20th, 2009 at 6:37 am and is filed under Uncategorized. You can follow
EXHIBIT “16”

2009
« from reader David Rachel

Chicago Protest, Where was all the news media on this one? »
Overview
Follow up on disappearing information and planted information.
I just got an e-mail from a woman by name Sue, I believe she is a lawyer. She is saying
that when she entered my name in the ABA registry, it was not there. Did somebody erase my
name from their on line registry to make me look not credible? Who did it?
What do we have so far:
1 Disinformation was planted one day before the election about a VA judge supposedly checking
Obama’s birth certificate and finding it to be valid and all challenges frivolous. No such case
ever existed, it was a planted fraud to create an illusion of Obama’s legitimacy and discourage
McCain voters one day before the election
2. one day after the election my case Lightfoot v Bowen was erased from the docket of the
Supreme Court. On march 13th I provided this info to chief Justice Roberts and nothing was
done.
3. my blog drorly.blogspot.com was destroyed. As readers tried to make comments, it would

crush. Google Jawa js -kit was blamed for it by the former web master Lisa Ostella, but nobody
knows, what was the reason
4. next blog defendourfreedoms.is went down several times- nobody knows why
5. e-mail address connected to my pay-pal was changed
6. my name is not on the ABA roster,even though it was supposed to be there
7. I discover 100 addresses for Obama, linked to 25 different ss numbers, report it to Holder,
Mueller, Sullivan, Roberts- no response
8. I discover 130 current job positions for Obama, report it - no response (dossier 1)
9. I confront William Chatfield- director of selective service with numerous evidence of forgery
in Obama’s selective service certificate- no response (Dossier4)
10. Forensic document examiner Sandra Ramsey Lines provides information and affidavit that
Obama’sCertificate of Live Birth cannot be relied upon as genuine, I report it- no response
(dossier 1 and 6)
10. Somebody erases from the National databases 110 addresses and job positions for Obama
and Michelle Obama, after those were already reported by me (Dossier 7)
11. somebody creates a a Scott Easterling blog and e-mail to assassinate the character of my
plaintiff active duty officer Scott Easterling and defame me and other plaintiffs- it is reported, no
response (dossier 1)
12. I uncover that Lisa Liberi, assistant for Philip Berg has an extensive criminal record in the
state of CA, including forgery of documents and grand theft. It was reported that Liberi was born
in the state of WA (I am verifying). Liberi has numerous social security numbers. Was she
planted to discredit the whole effort? I report it to Berg and recommend to go together to FBI and
demand investigation and to hire a forensic document examiner to check all the docs handled by
her. Instead Berg is filing a frivolous malicious law suit against me and everybody around, trying
to intimidate me and trying to keep me quite.
13. Berg is trying to obfuscate the truth by posting his office address in the pleadings as hers
even though she lives in Santa Fe NM and corresponds with Berg by e-mails and phone
while she is being supervised by the Santa Fe probation officers.
14. My husband just told me, that somebody posted on the Internet information from our
children’s birth certificates. How could that happen? Here I am working 24/7, trying to unseal
Obama’s BC with a compelling and a legitimate reason and nobody in our corrupt establishment
does a thing, and on the other hand somebody can unseal my children’s BC’s with no legitimate
reason. Why? To intimidate me some more? To threaten my kids? To show me that somebody
can do what ever he …likes and I cannot do a … about it?
15. Last year tampering into passport records of presidential candidates was announced. 3
employees were fired. I talked to one of them, he said nothing wrong was done, he sounded
pretty scared. One of the people involved Lt. Harris was found dead, shot in the head.
Will there be an end to this. I refuse to believe that we don’t have any decent people in our law
enforcement- there has to be somebody in FBI, CiA, police, sheriffs, judges, US attorneys, Atty
generals, DAs, state and US representatives, senators, SOS, governors. We need one person to
sign the …subpoenas.It has to be done Now!!!
In re to FBI, I called recently the cyber crimes detective Nathan Le, who was assigned to my
case, where this banner in Arabic, showing hanging of Saddam Hussein appeared on the site of a
man, who initiated erasing of an article about me from the Wikipedia. Detective Le told me, that
he needs to talk to his supervisor John Haas 714-542-8825. All the info was given to him, but I
believe this man is simply lazy and incompetent. When I talked to him last month, I told him to
look up something on his computer, he said that he is rather new, he has been at this department
only three months and the Internet is not hooked up to his computer yet. when I started laughing,
he didn’t even get the irony, in the fact that the supervisor of the cyber crimes unit is on the job
for three moths and doesn’t have the Internet hooked up yet?!? Guys, we are really in good
hands!
I called the police, Teresa Standiford is assigned to my case. She told me to file a new report
about the threats. The rest should be in Santa Fe as Liberi resides there.
North Brunswick police needs somebody to actually come to the station and file a report there.
Does anybody live close and can go to the station and file?
This nightmare has to end soon. Look the way our economy is being destroyed and our National
Security is being destroyed. We have to find somebody, who would do the right thing. I see that
Cheney started speaking up. He still has a lot of connections. Biden blubbered that Cheney
left Obama’s BC in the desk. Well, Mr. Cheney, it’s time.
This entry was posted on Friday, May 22nd, 2009 at 12:55 pm and is filed under Uncategorized. You can follow any
EXHIBIT “17”

2009
« Follow up MS+American Family Radio

Service of process to court sent 05.23.09. »
** DUPLICATES AND FEDERAL EXPRESS PICTURES REDACTED**
Berg
UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LIBERI §
And §
PHILIP J. BERG, ESQUIRE § CIVIL ACTION NO. 09-1898
And §
THE LAW OFFICES OF PHILIP J. BERG §
And §
EVELYN ADAMS a/k/a MOMMA E §
and §
LISA M. OSTELLA §
And § Assigned to Honorable Eduardo C.
GO EXCEL GLOBAL, § Robreno
§
Plaintiffs §
§
§
Vs. §
§
§
ORLY TAITZ, a/k/a DR. ORLY TAITZ, §
a/k/a LAW OFFICES OF ORLY TAITZ, §
a/k/a WWW.ORLY TAITZESQ.COM a/k/a §
WWW.REPUBX.COM a/k/a ORLY TAITZ §
And §
LINDA SUE BELCHER a/k/a LINDA S. §
BELCHER a/k/a LINDA STARR a/k/a §

NEWWOMENSPARTY a/k/a §
STITCHENWITCH a/k/a EVA BRAUN §
a/k/a WEB SERGEANT a/k/a KATY a/k/a §
WWW.OBAMACITIZENSHIPDEBATE.ORG §
And §
EDGAR HALE a/k/a JD SMITH, §
And §
CAREN HALE, §
And §
PLAINS RADIO NETWORK, §
a/k/a PLAINS RADIO NETWORK, §
INC. a/k/a §
PLAINS RADIO, §
And §
BAR H FARMS; §
And §
KPRN AM 1610; §
And §
DOES 1 through 200 Inclusive §
§
Defendants §
ANSWER
Defendants deny all allegations of wrong doing contained in the complaint.

Dated:
____________________
Dr. Orly Taitz, ESQ

26302 La Paz ste 211
Mission Viejo, CA 92691
Pro se and as the President of Defend our Freedoms Foundation on behalf of Defend Our
Freedoms Foundation.
Certificate of Delivery
I, Orly Taitz, certify that a true and correct copy of the foregoing was mailed to Philip Berg on
this 22 day of May, 2009 via Overnight Federal Express and via ForSure Legal Services Service
of Process, 250 Woodlake Dr. Holland PA 18966
_____________________
Orly Taitz
UNITED STATES DISTRICT COURT

LISA LIBERI §
And §
PHILIP J. BERG, ESQUIRE § CIVIL ACTION NO. 09-1898
And §
THE LAW OFFICES OF PHILIP J. BERG §
And §
EVELYN ADAMS a/k/a MOMMA E §
and §
LISA M. OSTELLA §
And § Assigned to Honorable Eduardo C.
GO EXCEL GLOBAL, § Robreno
§
Plaintiffs§
§
§
Vs. §
§
§
ORLY TAITZ, a/k/a DR. ORLY TAITZ, §
a/k/a LAW OFFICES OF ORLY TAITZ, §
a/k/a WWW.ORLY TAITZESQ.COM a/k/a §
WWW.REPUBX.COM a/k/a ORLY TAITZ §
And §
LINDA SUE BELCHER a/k/a LINDA S. §
BELCHER a/k/a LINDA STARR a/k/a §
NEWWOMENSPARTY a/k/a §
STITCHENWITCH a/k/a EVA BRAUN §
a/k/a WEB SERGEANT a/k/a KATY a/k/a §
WWW.OBAMACITIZENSHIPDEBATE.ORG §
And §
EDGAR HALE a/k/a JD SMITH, §
And §
CAREN HALE, §
And §
PLAINS RADIO NETWORK, §
a/k/a PLAINS RADIO NETWORK, §
INC. a/k/a §
PLAINS RADIO, §
And §
BAR H FARMS; §
And §
KPRN AM 1610; §
And §
DOES 1 through 200 Inclusive §
§
Defendants §
Motion to Dismiss Due to Lack of Jurisdiction

Here come the defendants Orly Taitz, pro se and Orly Taitz, President of Defend
Our Freedoms Foundation on behalf of Defend Our Freedoms Foundation and
allege the following:
1. Current action has no nexus to the State of Pennsylvania and no subject
matter jurisdiction. The defendants do not reside within this jurisdiction
within the meaning of 28 U.S.C.A. § 1391 (b) and the claim for which
this action arose is outside of this jurisdictional district. No federal
question is alleged in the complaint. Notwithstanding the above, the
defendants deny every allegation of the Plaintiff’s claim.
2. Above legal action stems from fraudulent use of name and Good Will of
Defend Our Freedoms foundation by web master Lisa Ostella,
(hereinafter Ostella) plaintiff in this action, resident of New Jersey and
financial benefit drawn by other plaintiffs in this action as a result of
Ostella’s activities.
3. Defend Our Freedoms foundation is registered in the state of California
by Orly Taitz, ESQ (Taitz, hereinafter), president of the foundation, resident
of the state of California as well. Initial registration form, State of
California, Office of the Attorney General, Registry of Charitable Trusts
submitted on December 17, 2008, Recorded in Orange County,
California 12.23.08
4. Orly Taitz never went by the name www.repubx.com and it is not an
a/k/a of Orly Taitz. Repubx.com is a web site/blog, owned by another
party, with no relation to this action.
5. www.orlytaitzesq.com is not a legal entity and not an a/k/a for Orly Taitz.
www.orlytaitzesq.com is a name of a blog/website run by Orly Taitz.
6. Orly Taitz, inc is not an a/k/a for Orly Taitz. It is a name of a dental
practice in California, incorporated and separate legal entity, with no
relation to current dispute.
7. Law offices of Orly Taitz are not an a/k/a for Orly Taitz. It is a name of a
law office with no relation to the dispute.
8. Plaintiff Lisa Liberi (hereinafter Liberi) is a Resident of the State of New
Mexico. Plaintiff’s attorney Philip Berg (Hereinafter Berg) has listed Liberi‘s
address to be an address of his office in Pennsylvania, however Liberi
does not reside in the state of Pennsylvania nor physically work in Berg’s
office in the state of Pennsylvania. Liberi is an assistant, who has some
legal background related to her own criminal convictions and who assists
Berg occasionally via e-mails, phone and mail sent from her residence in
New Mexico. Berg has improperly asserted her residence in Pennsylvania,
due to the fact that this is a state where he is licensed to practice law, in
order to try to obfuscate her real residence in New Mexico and
improperly bring a legal action in the state of Pennsylvania. Liberi claims
that she was defamed by Orly Taitz, disclosing to the public, Court
printout of Liberi’s convictions of forgery and grand theft. Taitz denies all
allegations and assets that all of the information provided was truthful
and convictions in question were in the state of California, (addendum 1

Printout of Liberi convictions in San Bernardino county, California) Liberi’s
prosecuting district Attorney James Secord is in San Bernardino County,
California; arresting officer and all of the detectives are in the state of
California, numerous victims of her criminal activity and potential
witnesses in this action are in the state of California, therefore a proper
jurisdiction for this action and forthcoming counter complaint is in the
state of California.
9. Liberi got an eight year term in January 2008 in California, she is currently
on probation and would be extradited back to California to serve her
term, if she indeed violated the conditions of her probation.
10. When Ostella fraudulently represented herself as Defend Our Freedoms
foundation and solicited donations for the Defend Our Freedoms
Foundation, Taitz has written a cease and desist letter to Ostella, Berg
and Adams, who were benefiting from Ostella’s activities.
11. When the above activity did not cease and desist, Taitz has filed a police
report, describing donations fraudulently misdirected from Defend our
freedoms foundation. The report 09-068339 was filed in the city of
registration of the foundation, Mission Viejo in the state of California,
which would be a proper jurisdiction in this action. (Addendum 2- Orange
County, California Recording for Defend Our Freedoms Foundation,
Addendum 3 Police report 09-068339)
12. Liberi, had developed a modus operandi of filing malicious and frivolous
law suits against victims of her criminal behavior, law enforcement and
judiciary in order to gain some advantage in her criminal prosecution
and in fact she has filed so many frivolous complaints and legal actions
against the District Attorney, District Attorney’s office, Presiding Judge,
police officers, detectives, her own defense attorneys, San Bernardino
County in California and even hospital, where she was treated, that as a
condition of her probation, she is obligated to properly clear with her
probation department any legal action she is planning to file. If Liberi did
not fulfill her obligation, probation will be revoked and she will be
extradited from New Mexico to California to serve her eight year prison
term, which makes California a proper Jurisdiction. (addendum 1 )
13. Most of victims of Liberi’s malicious and frivolous law suits reside in the
state of California, which would be a proper jurisdiction.
14. Liberi has gotten a reduction of her prison term to probation due to her
claim of being sick and disabled. Taitz has called District Attorney of San
Bernardino County James Secord and verified, that Liberi is on disability
and receiving disability payments from Social Security Administration. In
current case Berg states that Liberi is employed at his office. If indeed
Berg is paying or was paying Liberi a salary or any other payment directly
or indirectly through her husband Brent Liberi, while Liberi was receiving
social security payments for disability, that would constitute Social
Security fraud, violation of her probation and would be grounds for her
extradition to California to serve her eight year prison term, which makes
the state of California a proper Jurisdiction.
15. Due to the fact, that Liberi was convicted of economic crimes and
forgery of documents, as a condition of her probation, she is not allowed
to have any access to credit cards belonging to others or bank accounts
belonging to others. Berg’s office was handling a large donations drive. If

indeed Liberi directly or indirectly was handling credit cards or credit
card accounts of others, she will be in violation of her probation and will
be extradited to California, a proper jurisdiction in this case.
16. Due to the above, Berg, an attorney for Ostella, Liberi and Adams being
concerned that upon completion of the police investigation in California,
Taitz will file a legal action against his clients and him personally,
improperly filed a legal action in Pennsylvania with no nexus to the
dispute at hand, with the sole purpose of harassing and intimidating Taitz
and other defendants and trying to denigrate Taitz in anticipation of trial.
Due to the above defendants respectfully request dismissal of the current action
in the state of Pennsylvania due to lack of subject matter jurisdiction and
personal jurisdiction. Venue was improperly under 28 U.S.C.A. §1391 (b)
Wherefore, defendants demand judgment that the complaint be dismissed,

together with the costs and disbursements of this action.
Dated 05.21.09.
Dr. Orly Taitz ESQ
26302 La Paz, ste 211
Mission Viejo, CA 92691
Pro Se and on behalf of Defend our Freedoms Foundation and as a president of

Defend Our Freedoms Foundation
Addendum 1 Case FWV028000 - Defendants
Seq Defendant Next Court Date Status Agency / Arrest Date Count 1 Charge Violation Date
DR Number
1 LIBERI , LISA R RA 05/18/2001 PC 115(A) 05/18/2001

110013759
ALIAS: LIBERI, LISA R

ALIAS: COURVILLERICHARDSON, LISA
ALIAS: LIBERI, LISA A
ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: LIBERI, LISA RENEE
ALIAS: LIBERI, LISA
ALIAS: RICHARDSON, LISA RENEE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE - Status
Custody N/A
Filing Type Held to Answer Filing Date 05/09/2003
Ordered Bail $0.00 Posted Bail $0.00
D.A. James R. Secord Defense Dean Pitcl (Court Appointed)
Next Action: Deputy Report #: RA-RC 110013759
Warrant Type Status Issued Affidavit
NONE N/A N/A
Probation Type Granted Expiration
Formal 03/21/2008 03/21/2011
Sentence Convicted Date County Jail CTS
01/25/2008 26 Days 26 Days
State Prison Max Sentence
N/A N/A
Fine and Penalty Restitution Fine Restitution to Victim
0 N/A
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE - Charges
Arrest Charges
Count Charge Severity Description Violation Plea Status

Date
1 PC 459 F BURGLARY 05/18/2001
Filed Charges

Date
1 PC 487(A) F GRAND THEFT: PROPERTY/ETC 05/18/2001 HTA

OVER $400
2 PC 470(D) F FORGERY 05/18/2001 HTA
4 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 HTA

INSTRUMENT TO FILE

OVER $400
6 PC 470(D) F FORGERY 05/18/2001 HTA

INSTRUMENT TO FILE

OVER $400

OVER $400
11 PC F GRAND THEFT: 05/18/2001 HTA

487(D)(1) AUTOMOBILE/ANIMAL/ETC

OVER $400


OVER $400


OVER $400

OVER $400
Infor Charges

Date
1 PC 487(A) F GRAND THEFT: PROPERTY/ETC 05/18/2001 GUILTY CONVICTED

OVER $400
Case FWV028000 - Defendants
Seq Defendant Next Court Date Status Agency / Arrest Date Count 1 Charge Violation Date
DR Number
1 LIBERI , LISA R RA 05/18/2001 PC 115(A) 05/18/2001

110013759

ALIAS: LIBERI, LISA
Custody N/A
NONE N/A N/A
Formal 03/21/2008 03/21/2011
01/25/2008 26 Days 26 Days
N/A N/A
0 N/A

Arrest Charges

Date
1 PC 459 F BURGLARY 05/18/2001
Filed Charges

Date

OVER $400
2 PC 470(D) F FORGERY 05/18/2001 HTA

INSTRUMENT TO FILE

OVER $400
6 PC 470(D) F FORGERY 05/18/2001 HTA

INSTRUMENT TO FILE

OVER $400

OVER $400


OVER $400


OVER $400


OVER $400

OVER $400
Infor Charges

Date

OVER $400
2 PC F NONSUFFICIENT FUNDS: CHECKS 05/18/2001 GUILTY CONVICTED

476A(A)
3 PC 470(D) F FORGERY 05/18/2001 DISMISSED
4 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED
5 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED

INSTRUMENT TO FILE

OVER $400
7 PC 476 F MAKING, POSSESSING, UTTERING 05/18/2001 DISMISSED

FICTIOUS INSTRS
9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 DISMISSED

INSTRUMENT TO FILE

OVER $400

OVER $400
13 PC F GRAND THEFT: 05/18/2001 DISMISSED

14 PC 487(A) F GRAND THEFT: PROPERTY/ETC 05/18/2001 DISMISSED

OVER $400

16 PC 487(A) F GRAND THEFT: PROPERTY/ETC 05/18/2001 DISMISSED

OVER $400


OVER $400

OVER $400
20 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED

INSTRUMENT TO FILE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE - Probation
Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011
SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS

AND CONDITIONS:
1) SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR
TIME SERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO 1-
PC4019 ND ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT

THE POSSIBILITY OF COUNTY PAROLE.
2) VIOLATE NO LAW.
3) REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER

ONCE EVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB
OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCE EVERY FOURTEEN
(14) DAYS OR AS DIRECTED.
4) COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION AND

FOLLOW ALL REASONABLE DIRECTIVES OF THE PROBATION OFFICER.
5) SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ATTEND SCHOOL, AND KEEP THE
PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL.
6) KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND

COHABITANTS AND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER TWENTY-
FOUR (24) HOURS PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE
WRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAIL TO THE NEW
ADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS
OF THE PROBATION DEPT. AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF
ENSURING COMPLIANCE WITH PERMIT VISITS AND SEARCHES OF PLACES OF
RESIDENCE BY AGENTS OF THE PROBATION DEPT. AND/OR LAW ENFORCEMENT
FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT VISITS AND
SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT.
AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH
THE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHING TO INTERFERE
WITH THIS REQUIREMENT, OR DETER OFFICERS FROM FULFILLING THIS
REQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DO
ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM
FULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATES
THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON
THE PREMISES THAT WOULD REASONABLY DETER, ERECTING ANY LOCKED
FENCES/GATES THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE
ANY ANIMALS ON THE PREMISES THAT WOULD REASONABLY DETER, THREAT
THREATEN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM. EN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM.
7) NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR

DEADLY WEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE
DEVICES.
SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE AND/OR

PROPERTY UNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANY
LAW-ENFORCEMENT OFFICER, WITH OR WITHOUT A SEARCH WARRANT, AND WITH
OR WITHOUT CAUSE (PEOPLE -V- BRAVO).
9) NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICAL

PRESCRIPTION. A PHYSICIANS’S WRITTEN NOTICE IS TO BE GIVEN TO THE
PROBATION OFFICER.
10) SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION

OFFICER. EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY
CENTRAL COLLECTIONS
11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA, AS DEFINED IN H&S11364.5(D)
12) PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION

OFFICER, SUBMIT MONTHLY PROOF OF ATTENDANCE AND/OR SUCCESSFUL
COMPLETION TO THE PROBATION OFFICER AS DIRECTED AND BE RESPONSIBLE
FOR PAYMENT OF ALL PROGRAM FEE(S).
13) NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY

ENGAGED IN CRIMINAL ACTIVITY B-OR CODEFENDANT(S) OR VICTIM(S).
14) NOT ASSOCIATE WITH KNOWN ILLEGAL USERS OR SELLERS OF CONTROLLED

SUBSTANCES,
15) NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETE OR ENDORSE ANY CHECKS

UNLESS MADE PAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOUR
POSSESSION WITHOUT PERMISSION OF THE PROBATION OFFICER.
16) SUBMIT A RECORD OF INCOME AND EXPENDITURES TO THE PROBATION OFFICER

QUARTERLY.
17) NEITHER POSSESS NOR USE ANY CREDIT CARD WITHOUT PERMISSION OF THE
PROBATION OFFICER.
18) NOT DRIVE OR POSSESS KEYS OR DOCUMENTATION TO ANY MOTOR VEHICLE

UNLESS LEGALLY REGISTERED TO YOU OR AN IMMEDIATE FAMILY MEMBER,
EXCEPT IN THE COURSE OF EMPLOYMENT.
19) REPORT ALL MOTOR VEHICLES REGISTERED TO YOU TO THE PROBATION OFFICER
WITHIN SEVEN (7) DAYS OF ACQUISITION.
20) SUBMIT TO AND COOPERATE IN A FIELD INTERROGATION BY ANY PEACE OFFICER

AT ANY TIME OF THE DAY OR NIGHT.
21) CARRY AT ALL TIMES A VALID DRIVERS LICENSE OR DEPARTMENT OF MOTOR

VEHICLES IDENTIFICATION CARD AND DISPLAY SUCH IDENTIFICATION UPON
REQUEST BY ANY PURPOSE WITHOUT FIRST NOTIFYING THE PO. CONTAINING
YOUR TRUE NAME AGE AND CURRENT ADDRESS
22) ENROLL IN THE DRUG TREATMENT PROGRAM AT THE DIRECTION OF THE

PROBATION OFFICER, AND SHOW PROOF OF ENROLLMENT TO THE PROBATION
OFFICER WITHIN SEVEN (7) DAYS.
23) MAKE RESTITUTION TO THE VICTIM(S) (SEE PROBATION REPORT) IN THE AMOUNT
OF $9223.77 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS
24) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AM OUNT OF
$35000.00 PLUS A 10% ADMINISTRATIVE FEE, TO BEPAID THROUGH CENTRAL
COLLECTIONS
25) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AMO UNT OF
$66951.08 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS
26) PAY A RESTITUTION FINE IN THE AMOUNT OF $200.00, PLUS A TEN PERCENT (10%)
ADMINISTRATIVE FEE THROUGH CENTRAL COLLECTIONS.
27) THE DEFENDANT IS NOT TO FILE ANY LAWSUIT/LEGAL ACTION WITHOUT PRIOR
CONTACT WITH PROBATION OFFICER.
28) DO NOT APPLY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH
PROBATION OFFICER.
29) COMPLY WITH ANY COURT-ORDERED PAYMENT SCHEDULE.
30) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE

DETERMINED BY PROBATION.
31) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE

DETERMINED BY PROBATION.
32) PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN

THE STATE OF NEW MEXICO UPON APPROVAL FROM PROBATION.
Tags: birth certificate, crimes Lisa Ostella, eligibility, Lisa Liberi, natural born citizen
This entry was posted on Thursday, May 28th, 2009 at 2:36 am and is filed under Supporting Documentation,
Uncategorized. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are
currently closed.
EXHIBIT “18”
** Note, the below emails are fabricated and altered emails all proof of which has been
filed in the lower Court in different pleadings **

2009
« From reader Bob S. Did anyone see Hank Paulson coming out of his house lately?
Re Keyes v Obama »
I am trying to stay away from Liberi-Berg issue, but i got more

questions and here is more info.
I was asked by a number of people to explain why the name of Lisa Ostella is on the dossier #4.
When I was in Washington DC, I did not have an access to the Internet, as I was visiting the
Director of the Selective Service William Chatfield and offices of several senators and was on
the phone with the assistant and legal counsel for Admiral Malin. A lot of people asked me for
an update and I called Lisa Ostella, the web master ,and asked her to post it on the Internet. As
you can see, the fact that she signed DefendOurfFeedomsFoundations, and she put her name as
an assistant to me, clearly shows that she knew it is my foundation, under my name and
she could sign as an assistant only as long as she was helping me. The moment I transferred to
another webmaster, she had and has no right to advertise on behalf of the DefendOurFreedoms
foundation, solicit donations and pocket the money.
You can also see (in the attachment) that she was the one that contacted the private investigator
Mr. Sankey, and provided him the information that Lisa Liberi , assistant to Phil Berg, has a
criminal record. Based on her report Mr. Sankey has investigated and confirmed this
information, that indeed Lisa Liberi has this lengthy record of forgery of documents and forgery
of an official seal and grand theft. Lisa Ostella changed her tune only after this whole issue with
pay-pal came out. At first she and the rest of the plaintiffs came out with an outrageous lie that
my husband was spying on people. Now they dismissed their law suit against my husband- and
everybody knows that it was a manufactured charge.
As you can see, she was well aware about Liberi’s criminal record, as was Berg and Liberi
herself. Their legal action is nothing but perjury and an attempted obstruction of justice. I have
written in the pleadings that the only address that Liberi provided, was Berg’s office address
and the reason is that she indeed resides in NM and is the Lisa Liberi with the criminal record. I
received an e-mail recently that in the last couple of days Lisa Liberi has gotten a PA drivers
license. If she got one in the last couple of days, that doesn’t change the fact that she resided in
NM and that all of them committed perjury. If anything, getting a PA drivers license now is
yet another attempt to obstruct justice.
As I have said before, I don’t get intimidated by either Obama or by Berg. One cannot file a
fraudulent and malicious legal action against me and expect to shut me up and make me stop
reporting on illegal and criminal activity. All that these people are doing, is adding counts of
fraud, perjury and obstruction of justice. The only thing Berg can do, is come clean, disassociate
himself from Lisa Liberi, who has a record of forgery and he needs to hire a forensic document
examiner to check all the records handled by Lisa Liberi. We cannot win in court with forged
records. This information was already on the blogs before I got it and it will be on the blogs, his
continuing denial of clear evidence has no merit and undermines everybody in the resistance
movement, everybody who wants to get to the truth. The only way to win, is by clean evidence,
unsealing the vital records and letting the Supreme Court decide the issue of the Natural Born
Citizen.
> From: nsankey@thesankeyfirm.com

> To: lisaostella@hotmail.com
> Subject: RE: HELLO ??? (again)
> Date: Sun, 15 Mar 2009 17:02:00 -0700
>
> Indeed it would. If you would pass this on to Dr.O, I will go out to San Bdo
> this week and have a look at the 2002 file, dontcha think?
>N
>
> —–Original Message—–
> From: Lisa Ostella [mailto:lisaostella@hotmail.com]
> Sent: Sunday, March 15, 2009 4:49 PM
> To: Neil Sanky
> Subject: RE: HELLO ??? (again)
>
> Hmm, if the forged documents actually came out of Phil Berg’s office, well,
> filing lawsuits would be an excellent cover, huh?
>
> Factcheck is in Pennsylvania.
>
> As is Phil Berg.
>
>
> Lisa Ostella
> Defend Our Freedoms Foundation
> http://defendourfreedoms.org <http://defendourfreedoms.org/>
> Peace through Strength
> http://www.barofintegrity.com <http://www.barofintegrity.com/>
>
>
>
>
>
>
>
>
> > From: nsankey@thesankeyfirm.com
> > To: lisaostella@hotmail.com
> > Subject: RE: HELLO ??? (again)
> > Date: Sun, 15 Mar 2009 16:35:46 -0700
>>
> > Yes but a SEAL !!, and HOW MANY aliases?
>>
> > —–Original Message—–
> > From: Lisa Ostella [mailto:lisaostella@hotmail.com]
> > Sent: Sunday, March 15, 2009 3:46 PM
> > To: Neil Sanky
> > Subject: RE: HELLO ??? (again)
>>
> > Insight, such as, Lisa Liberi (Phil Berg’s assistant) really being Lisa
> > Richards, with a police record for ID theft?
>>
> > Mighty convenient talent to have when there are multiple identities flying
> > around.
>>
> > I’ve not researched that insight yet. I didn’t have a warm and fuzzy
> > interaction with (redacted name of volunteer )So I don’t know if this is planted info
droppings
> > or not.
>>
>>
> > Lisa Ostella
> > Defend Our Freedoms Foundation
> > http://defendourfreedoms.org <http://defendourfreedoms.org/>
> > Peace through Strength
> > http://www.barofintegrity.com <http://www.barofintegrity.com/>
>>
This entry was posted on Sunday, May 31st, 2009 at 2:19 pm and is filed under Uncategorized. You can follow any
EXHIBIT “19”
http://www.orlytaitzesq.com/blog1/?m=200906&paged=7

2009
Monday, June 15th, 2009
Update on Berg
I really tried to stay away from the frivolous action by Philip Berg, as I think it is just a
distraction and a waste of my time, however since he filed a legal action and he issues
frequent press releases with outrageous slanderous statements about me, I have to
respond.
This is not the first time Berg brings an action with manufactured allegations. Please
see an attachment below showing Berg being sanctioned by the court and fined over
$10,000 for bringing a frivolous baseless law suit with the sole purpose of harassing the
other party.
In regards to his legal actions- the one that he called a law suit under seal, was actually
not a law suit but a request for Atty. General to file a law suit. It was stating that Obama
is not only not a Natural Born Citizen, but not a citizen at all, which is harder to prove, as
he could’ve become a citizen at any time. The request, filed by Berg, was asking the
Attorney General to take back Obama’s salary of the senator, whereby Berg were to get
a certain percentage of it, as a whistleblower. I was just skeptical about the viability of
such a request.
In regards to two other legal actions he filed, they were dismissed and from January
Berg was saying that he has an oral argument scheduled for May. The month of May
came and went and there was no argument and nobody could find any such argument
scheduled on the docket. Now he is saying that there is an argument scheduled for
September-October, but again nobody can find anything scheduled.
The only law suit he has going, is one with slanderous allegations against me and his
only occupation as of late has been issuing outrageous press releases about me and
asking for money so he can slander me some more and can file more law suits against
me. It is just despicable that Berg, who was sanctioned by the court and fined for
bringing frivolous action with the sole purpose of harassment is calling to have me
disbarred, that Berg, who is employing Lisa Liberi, a convicted criminal, with 10 felony
convictions of grand theft, forgery of documents and forgery of seal (see record
attached), is accusing others of forgery and fraud, including a licensed investigator with
20 years of experience in Scotland Yard and over 15 years of experience, Mr. Sankey,
a Christian minister and editor of Christian publishing Pastor James Sundquist, a radio
station, a talk show host, the wife of a talk show host and even their own volunteer. I
have attached a copy of the second amended motion to dismiss due to lack of
jurisdiction. I was asked –what does it mean. You are supposed to file such a motion
first, as if there is no jurisdiction the case is dismissed right then and there before it
goes any further. I hope Eastern District Court of Pennsylvania judge Eduardo Robreno
will dismiss this case shortly.
Since my foundation Defend Our Freedoms Foundation (DOFF) is registered in

California, I have filed a complaint with the Attorney General of California, Orange
County FBI and Mission Viejo, Orange County Police, asking them to investigate
actions by Lisa Ostella, Lisa Liberi, Evelyn Adams and Philip Berg, whereby Lisa Ostella
is fraudulently diverting donations from DOFF to her own pocket and Liberi, Adams and
Berg are being unjustly enriched by her actions and their own actions.
I have also included a list of legal actions and initiatives I am currently spearheading. I
am asking for your support and follow up with governmental officials. I firmly believe that
unsealing of Obama’s records is only a first step in the direction of the true transparency
in government, that there is a long way ahead in turning around this economy. It will not
improve with empty slogans of hope and change and wasting billions of dollars on un-
stimulating stimulus, which stimulates only the printing press, that prints funny money,
which soon will be less valuable then money from Toys R Us. This economy will not
change and improve by giving billions to the thugs from Acorn, the thugs from Hamas
and the crooks from AIG transferring 59% of the stimulus to stimulate foreign banks.
We will achieve true economic growth and improvement, when we realize that the free
market economy benefitted only a few billioners, It bankrupted this whole country. We
need to go back to sanity, we need balanced trade, we need balanced budget for each
and every state and the country in general, we need to fight governmental corruption,
we need to start producing again. This is a monumental task. It will take more then one
or two lawyers to make a difference. It will take each and every one of you working 24/7
to turn this country around. Please go through the list. I need a couple of volunteers to
go through the earlier posts and insert the contact info for the officials. Please, form
lobbying groups and don’t take no for an answer. We need to reach each and every law
enforcement and governmental official and we need to make all of them accountable.
Any official, who violates the Constitution and his oath of office and allows fraud and
treason, will be held accountable by the citizens of this country. Please join 4th of July
tea parties and September 12-13 Nation Renewal million men march on Washington. I
will be speaking there.
Lawyer Slapped With $10K in Sanctions for ‘Laundry List of Unethical Actions’
Shannon P. Duffy
The Legal Intelligencer
July 25, 2005
Printer-friendly Email this Article Reprints & Permissions
Finding that a Pennsylvania lawyer had committed a “laundry list of unethical actions,” a federal
judge has imposed more than $10,000 in sanctions and ordered the lawyer to complete six hours
of ethics training.
U.S. District Judge J. Curtis Joyner’s 10-page opinion in Holsworth v. Berg is packed with
criticism of the conduct of attorney Philip Berg of Lafayette Hill, Pa.
“Other attorneys should look to Mr. Berg’s actions as a blueprint for what not to do when
attempting to effectively and honorably perform the duties of the legal profession,” Joyner wrote.
“This court has grown weary of Mr. Berg’s continuous and brazen disrespect toward this court
and his own clients. Mr. Berg’s actions … are an enormous waste of judicial time and resources
that this court cannot, in good conscience, allow to go unpunished,” Joyner wrote.
In the suit, Berg is accused of legal malpractice by former clients who claim his failure to
respond to an ERISA claim against them led to a default judgment.
But the sanctions against Berg stem from his decision to file a third-party counterclaim of fraud
against a pension fund that had sued his former clients, according to court papers.
Joyner blasted Berg for filing the fraud claim, calling it an “irresponsible decision” because the
claim was “utterly barren of any scintilla of legal principles.”
In the ERISA suit, Berg’s former clients — Richard Holsworth and his company, Richard’s
General Contracting — were sued by a group of pension funds led by the Carpenters Health and
Welfare Fund of Philadelphia and Vicinity.
Carpenters Health claimed that Holsworth and his company had failed to make required payment
of fringe benefit contributions.
According to court papers, Joyner found that Berg “neglected to file a response to [Carpenter
Health's] claim or provide any legal defense whatsoever for his client.”
Even after a default judgment was entered against Holsworth, Joyner found that Berg “remained
silent.”In April 2002 — two months after the default judgment was granted and 11 months after
the suit was first filed — Joyner found that Berg “broke his silence” by filing a petition to strike
the judgment or to open the default judgment.
Berg’s motion was rejected and a default judgment of more than $5,300 was entered against his
clients.The judgment swelled to more than $10,000 when Carpenters Health later successfully
moved for a supplemental judgment to recover more than $4,700 in attorney fees for its efforts in
responding to Berg’s untimely motions.
Holsworth and his wife later filed a legal malpractice suit against Berg in the Philadelphia
County Court of Common Pleas, alleging that Berg negligently failed to represent them in the
Carpenters Health case.
A year later, in February 2005, Berg moved to join Carpenters Health as a third-party defendant
in the malpractice suit, demanding more than $20,000 in damages.
In his counterclaim, Berg alleged that the ERISA suit filed by Carpenters Health in 2001, which
led to the malpractice claim against him, was “a fraud upon the court and a fraudulent taking
from the Holsworths.”
Carpenter Health’s lawyers removed the case to federal court and filed a motion to dismiss the
claim.Joyner agreed, finding that Berg’s fraud claim was “frivolous” and was motivated by an
intent “to harass Carpenters Health and the Holsworths, as well as to delay and disrupt the
administration of justice.”
The claim was fatally flawed, Joyner found, because Berg had no standing to bring suit against
Carpenters Health and had “failed to conduct even a minimally reasonable inquiry before filing
his complaint.”
Granting summary judgment in favor of Carpenters Health, Joyner said he found it “wholly
unnecessary” even to consider the facts of the ERISA case because it was “abundantly clear” that
Carpenters Health was entitled to a judgment as a matter of law.
Joyner invited Carpenters Health to file a motion for Rule 11 sanctions. When it did, Joyner
found that Berg “continued his trend of unprofessional conduct by, once again, failing to file a
timely response.”
In a footnote, Joyner said Berg’s response to the sanctions motion was due on May 26. In a
phone call to chambers on May 31, Joyner said, Berg’s assistant requested permission to move
for an extension of time, saying Berg had been out of town for two or three weeks and would not
be returning until June 9.
Joyner said he agreed to accept such a request if it were filed the next day, but none was.
Instead, Joyner said, a letter signed by Berg’s assistant was faxed to chambers on June 2,
requesting that the deadline be extended until June 27.
Joyner said he refused because “in light of Mr. Berg’s persistent and repeated neglect of his
professional obligations, this court was not inclined to permit Mr. Berg to further delay the
review of Carpenters Health’s ripe motion.”
In a June 2 opinion, Joyner found that Berg had violated Rule 11 by “filing a complaint
completely devoid of any basis in fact or law, as would be apparent to any reasonable attorney
after the slightest inquiry.”
Berg’s fraud claim, Joyner said, was “inadequately pled, not grounded in fact, time-barred, and
utterly irrelevant to the pending malpractice action against him.”
In his sanctions order, Joyner ordered Berg to reimburse Carpenters Health the $10,668 in
attorney fees and costs it incurred in defending the claim. He also ordered Berg to complete six
credits of ethics courses certified by the Pennsylvania Board of Continuing Legal Education, and
recommended that Berg be investigated by the Pennsylvania Bar Association’s Committee on
Legal Ethics and Professional Responsibility.
On June 16, Berg filed a motion for reconsideration urging that the sanctions imposed on him
should be forgiven due to “extenuating circumstances,” including health problems, a three-week
European business trip and financial difficulties.
Berg conceded in his brief that “there were numerous procedural errors, untimely responses and
omissions,” but said he “did not do so with intention or defiance.”
Joyner flatly rejected the motion, saying “in no way, shape or form do the ‘extenuating
circumstances’ proffered by Mr. Berg even begin to justify, excuse, or explain his unprofessional
and unethical course of conduct throughout this matter. These transparent excuses are not only
patently insufficient to meet the legal standard for a motion for reconsideration, they are
insulting to this court and demeaning to the legal profession.”
Berg, reached in his office, declined to comment on Joyner’s decision except to say that he is
considering whether to file an appeal.
Carpenters Health was represented by attorneys Sanford G. Rosenthal and Eric B. Meyer of
Jennings Sigmond.
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Dr. Orly Taitz, pro se
Orly Taitz Law Offices
26302 La Paz, Suite 211
Mission Viejo, California 92691
(949) 683-5411
dr_taitz@yahoo.com
UNITED STATES DISTRCT COURT

Lisa Liberi, et al., §

Plaintiffs, §
§
v. § Civil Action No. 2:09-cv-01898-ER
§
Orly Taitz, et al. §
Defendants §
SECOND AMENDED MOTION TO DISMISS COUNTS ONE-SIX FOR 12(b)(1)

LACK OF SUBJECT MATTER JURISDICTION &
JUDGMENT ON THE PLEADINGS
It has long been the case that the jurisdiction of the Court depends upon the state
of things at the time of the action brought.” Mollan v. Torrance, 22 U.S. 537, 9
Wheat. 537, 539, 6 L. Ed. 154 (1824). This time-of-filing rule is hornbook law
(quite literally) [*571] taught to first-year law students in any basic course on
federal civil procedure. It measures all challenges to subject-matter jurisdiction
premised upon diversity of citizenship against the state of facts that existed at the
time of filing–whether the challenge be brought shortly after filing, after the trial,
or even for the first time on appeal. (Challenges to subject-matter jurisdiction can
of course be raised at any time prior to final judgment. See Capron v. Van
Noorden, 6 U.S. 126, 2 Cranch 126, 2 L. Ed. 229 (1804).
Grupo Dataflux v. Atlas Global Group, L.P., 541 U.S. 567 at 570-71; 124 S.Ct. 1920 at 1924;
158 L.Ed.2d 866 at 872 (2004).
Without wishing to minimize the appearance created by the volume of paperwork filed to
date in this above-entitled-and-numbered civil action, the case ends here or it ought to. Count
One is labeled as and would apparently pretend to be a federal cause of action, in its title only,
but it is at best a California statutory suit for violation of privacy, and must accordingly be
evaluated, for subject matter jurisdiction, under the same diversity of citizenship analysis applied
to the state-labeled Counts Two through Six.
The only colorable basis for Federal Court subject matter jurisdiction over the state-law
“substance” (without conceding, in fact, that there is any substance) of Counts Two (Complaint
p. 66 ¶¶158-166: “Defemation[sic], per se, Slander and Libel”), Three (Complaint p. 69, ¶¶167-
173: False-Light Invasion of Privacy), Four (Complaint p. 72, §§174-181: “Harassment”), Five
(Complaint p. 75, ¶¶182-189: “False Designations and Descriptions of Facts”), and Six
(Complaint p. 78, ¶¶190-196: “Injunctive Relief” as to “defamation,” “false allegations,”
“misrepresentations of their character” and “false light”) would be diversity of citizenship, as is
alleged in paragraph 1 on page 4 of the original (and only) Complaint, filed in this case on May
4, 2009.
All of these “Counts” are woefully insufficient as a matter of competent federal practice
and pleading, but none of these counts contain even the suggestion of a conceivable much less
plausible cause of action arising under Federal Law, so diversity is the only imaginable basis for
jurisdiction and the federal standards for diversity are neither novel nor difficult to apply: the
Complaint reveals on its face that “complete diversity of citizenship” between Plaintiffs and
Defendants simply does not exist, and cannot be cured by amendment because jurisdiction is
established by the case initial “snapshot” of the parties, not later changes.
Dr. Orly Taitz admits that she is a dentist, by primary profession, and although admitted
to practice in the State of California and several federal courts, she is not primarily a litigator.
Defendant also admits that “ignorance of the law is no excuse,” but would nevertheless submit
that “A party cannot inadvertently or intentionally (e.g. by agreement) waive its right to object to
the Court’s lack of subject matter-jurisdiction.” Insurance Company of Ireland, Ltd., v.
Compagnie des Bauxites de Guinee, 456 U.S. 694 at 702, 102 S.Ct. 2099 at 2104 (1982). And
since Strawbridge v. Curtiss, 7 U.S. 267, 3 Cranch 267, 2 L.Ed. 435 (decided February 13,
1806), the United States Supreme Court has read the statutory formulation “between . . . citizens
of different States,” 28 U.S.C. § 1332(a)(1), to require complete diversity between all plaintiffs
and all defendants. So, every other objection and contention the parties have made up to this
point set aside, the case ends here, for the following reasons which Defendant Dr. Orly Taitz
inadvertently failed to raise in her previous motions and answer:
On the first (title) page of Philip J. Berg’s Complaint for Damages, with Jury Trial
Demanded, filed on May 4, 2009, and never amended or otherwise superceded, Lisa M. Ostella
and Go Excel Global are identified as Plaintiffs while James Sundquist and Rock Salt Publishing
are identified as Defendants. In paragraphs 8 and 9 on page 5 of the May 4, 2009, complaint,
Lisa M. Ostella is identified as residing at 2227 US Highway 1, #245, North Brunswick, New
Jersey 08902-4402 with her principal place of business at the offices of Plaintiff Go Excel
Global, also in North Brunswick, New Jersey 08902-4402.
On page 6 of the May 4, 2009, complaint, in paragraphs 16-17, a Defendant James
Sundquist and his principal place of business Rock Salt Publishing are identified as having a
business address of 551 Valley Road, Suite 123, Upper Montclair, New Jersey 07043.
The undersigned Defendant has previously argued and submitted evidence that Plaintiff
Lisa Liberi should be deemed a citizen of California for purposes of diversity, on account of her
long-time residence and criminal history and multiple convictions and status as a probationer in
Defendant Orly Taitz’ home state[1]. While Defendant still contends that her analysis of Lisa
Liberi’s citizenship for purposes of Strawbridge v. Curtiss “complete diversity” analysis is
correct, it is upon reflection mere surplusage, at this point, because the paired Plaintiffs Lisa
Ostella and her Go Excel Global, when paired against the paired Defendants James Sundquist
and his Rock Salt Publishing, as identified and described expressly and explicitly ON THE
FACE OF PLAINTIFFS’ OWN COMPLAINT, completely and effectively destroy any
contention of “complete diversity.” Even if Defendants Dr. Orly Taitz and her “Defend Our
Freedoms Foundations, Inc.” should be deemed to have defaulted so egregiously as to have
confessed the well-pled allegations (if any) of the Plaintiffs’ Complaint, such a default is not and
cannot be taken as a waiver of objections to subject matter jurisdiction. Without subject matter
jurisdiction, which can only be established by the well-pled allegations of Plaintiffs’ Complaint,
this United States District Court is entirely without power to proceed, to entertain any part of
Plaintiffs’ Complaint, or to afford to Plaintiffs’ any relief whatsoever.
FAILURE TO IDENTIFY FEDERAL QUESTION CAUSES OF ACTION
(FRCP RULES 12(b)(6) & 12(c) JUDGMENT ON THE PLEADINGS)

For purposes of the present motion, Defendant Dr. Orly Taitz submits that the Plaintiffs
have failed even to identify any actual or conceivable Federal question Causes of Action in their
May 4, 2009, Complaint, and are thus subject to Judgment on the Pleadings pursuant to Rule
12(c). Much less have the Plaintiffs actually pled any plausible Federal Causes of Action with
anything approaching the specificity required by Rule 12(b)(6) as construed and applied under
the Supreme Court’s latest evaluation Bell Atlantic v. Twombly, 550 U.S. 544; 127 S. Ct. 1955 at
1964-65; 167 L.Ed.2d 929 (2007). In fact, it is fair to say, paraphrasing the language of
Twombly, that the Plaintiffs Liberi et al. have not even made the conclusory allegations, or
sufficient factual allegations to identify the “labels and conclusions” necessary to constitute a
“formulaic recitation of the elements of any causes of action” arising under Federal statutes or
jurisprudence, whatsoever. Count One, as noted above, is basically a “sham” based on a content-
free title including two Constitutional Amendments not mentioned again in any paragraph.
In relation to Counts Two through Six, which bear state court “labels” and little else
suggesting any theory of recovery at all, there are repeated but vague references to Defendants’
“posting and distributing Liberi’s social security number” and then, on page 73, ¶180, that
“Defendants have acted unlawfully and in violation of” several federal statutes without more in
the way of material factual allegations. Such sloppy “pleading” was not permitted in Federal
Court prior to Twombly, but it is clearly frivolous and sanctionable now after the Supreme
Court’s decision in that case.
This leaves COUNT ONE of Plaintiffs’ May 4, 2009, Complaint, at page 60, ¶¶ 144-157
for analysis. “COUNT ONE” is entitled “VIOLATION OF THE FIRST AND FOURTEENTH
AMENDMENT OF THE UNITED STATES CONSTITUION [sic] and ILLEGAL
DISCLOSURE OF AN INDIVIDUAL’S SOCIAL SECURITY NUMBER AND PERSONAL
IDENTIFYING INFORMATION”. While the First and Fourteenth Amendments of the United
States Constitution would appear to frame federal issues, no federal civil rights (nor any other)
statutes are cited until paragraph 157. In fact, no statutes or case law authorities are cited until
paragraph 151, and the subsequent paragraphs focus exclusively on California Civil Code
§§1798.81-1798.85” along with vague reference to (other?) “California privacy laws” as
providing possible grounds or factual frameworks for liability or recovery. Accordingly the
mere recitation of two constitutional amendments in the FEDERAL CONSTITUTIONAL
TITLE of Count One should be disregarded, and judgment entered on the pleadings in this case
pursuant to Rule 12(c) of the Federal Rules of Civil Procedure, or in the alternative under
12(b)(6) because no conceivable Federal law theories of recovery are stated or even identified in
Count One.
As in paragraph 180 on page 73, discussed above, paragraph 157 on pages 63-64 contains
random citations to several federal laws, but the factual allegations of this paragraph are so
vague, conclusory, and general, without reference to any specific outline of any causes of action
recognized or established by federal law, that there is no substantial basis for the exercise of
federal question jurisdiction. Count One may contain more “Federal Words” in its title than the
other counts of Plaintiffs’ May 4, 2009 complaint, but it does not contain more “Federal
Substance” and should be dismissed along with Counts Two through Six as an attempt to utilize
federal diversity jurisdiction to sue and impose liability under what is, at the absolute most,
examining the Complaint in the light most favorable to the Plaintiffs, as nothing more nor less
than an extremely poorly pled California state cause of action.
PRAYER FOR RELIEF

Judgment should accordingly be entered in favor of all the Defendants dismissing the May 4,
2009, Complaint for Want of Subject Matter Jurisdiction pursuant to Rule 12(b)(1), Failure
to State a Claim upon which Relief can be Granted pursuant to Rule 12(b)(6), or in the
alternative for Judgment on the Pleadings pursuant to Rule 12(c). The scattered references to
federal statutes or constitutional amendments do not add up to any cognizable theory of
recovery under federal law, and since complete diversity of citizenship between the Plaintiffs
and Defendants is lacking, the May 4, 2009, Complaint in this case should be dismissed with
prejudice to the refiling of the same in any federal court anywhere, for any purposes.
Defendants Dr. Orly Taitz and Defendant our Freedoms Foundations, Inc., accordingly move
and pray for complete dismissal of the Complaint filed by Lisa Liberi, Philip J. Berg, the
Law Offices of Philip J. Berg, Evelyn Adams a/k/a Momma E, Lisa M. Ostella, and Go
Excel Global, and ask that all Defendants be released from further liability to appear or
answer in this case, and that all proceedings in this case be adjourned sine die.
Respectfully submitted,
Wednesday, June 10, 2009
By:________________________________
Defendant, in propia persona and on behalf
of Defend Our Freedoms Foundations, Inc..
Dr. Orly Taitz, President,
Telephone (949) 683-5411

E-Mail: dr_taitz@yahoo.com
This report came from volunteer Sarah redacted

Case FWV028000 - Defendants
Seq Defendant Next Court Status Agency / Arrest Date Count 1 Violation Date
Date DR Number Charge
1 LIBERI , LISA RA 05/18/2001 PC 115(A) 05/18/2001
R 110013759
ALIAS: LIBERI, LISA
Custody N/A

NONE N/A N/A
Formal 03/21/2008 03/21/2011
01/25/2008 26 Days 26 Days
N/A N/A
0 N/A
Arrest Charges
Date
1 PC 459 F BURGLARY 05/18/2001

Filed Charges
Date

487(A) PROPERTY/ETC OVER $400
2 PC F FORGERY 05/18/2001 HTA
470(D)
4 PC F OFFER/ETC FALSE/FORGED 05/18/2001 HTA
115(A) INSTRUMENT TO FILE
6 PC F FORGERY 05/18/2001 HTA
470(D)
8 PC F OFFER/ETC FALSE/FORGED 05/18/2001 HTA
Infor Charges
Date
1 PC F GRAND THEFT: 05/18/2001 GUILTY CONVICTED

2 PC F NONSUFFICIENT FUNDS: 05/18/2001 GUILTY CONVICTED

476A(A) CHECKS
3 PC F FORGERY 05/18/2001 DISMISSED
470(D)
5 PC F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED
7 PC 476 F MAKING, POSSESSING, 05/18/2001 DISMISSED
UTTERING FICTIOUS INSTRS
470(D)
9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC F OFFER/ETC FALSE/FORGED 05/18/2001 DISMISSED
20 PC F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED
470(D)
470(D)
List of initiatives and legal actions spearheaded by Orly Taitz
1. Keyes et al v Obama et al filed in Central District of CA.

2. Easerling et al v Obama et al submitted to SCOTUS
3. Lightfoot et al v Bowen was filed in the Supreme Court of CA and later in SCOTUS. It
was referred by Chief Justice Roberts for conference on January 23, however it did not go
to oral argument.
4. Co-authored Keyes et al v Bowen.
5. James et al v Obama demand for Quo Warranto submitted to the US attorney for the DC
Jeffrey a Taylor, who has resigned. Demand for the new acting US attorney for the DC to
file Quo Warranto against Obama
6. Quo Warranto demand was submitted to Atty gen. Eric Holder. A phone call was
received stating that the Dossiers were forwarded to the Criminal division of the DOJ.
7. Pro Hac Vice appearance was made on behalf of Jody Brockhausen and a complaint was
filed with the US attorney for the western District of TX for criminal Matters Richard
Durbin and assistant US atty Chris Peel.
8. 8 dossiers describing suspected illegal activity perpetrated by Obama and his supporters
was submitted to Holder
9. Request for criminal investigation of Obama’s Selective Service Certificate and
Certification of Live Birth with numerous signs of perjury was forwarded to the
Beaumont police (Obama campaigned in Beaumont) on behalf of a number of clients.
10. After the chief of Beaumont police told officer Dischler not to investigate, due to the fact
that it is a political issue and after the officer was threatened that the Chief of Police will
investigate him, a criminal complaint was forwarded to the US attorney for the Eastern
District of TX Rebeccah Gregory. Ms. Gregory resigned, the complained will be handled
by the successor.
11. Copy of the complaint was forwarded to Governor Perry on May 5th. On May 6th the
legal counselor for the governor referred us to the DA of Jefferson County Tom Manness.
12. All of the dossiers and the complaint were forwarded to DA Manness and Chief
investigator Rose as well as the San Antonio DA Susan Reed.
13. Dossiers were either hand delivered by me or sent by certified mail to each and every
member of the Senate Judicial committee, as well as Senator Thune of Armed Services
Committee and Senator Grassley of Finance Committee and Senator Feinstein, who was
the chair of Intelligence committee.
14. Dossiers were forwarded to Robert Mueller –director of FBI
15. Dossiers were forwarded to Mark Sullivan, Director of Secret service
16. Dossiers were forwarded to Captain James Crawford, legal counselor for Admiral Mike
Mallin, chairman of the Joint Chiefs of staff (response is expected shortly)
17. Dossiers were forwarded to Steven Whitlock, director of the whistle blower office of the
IRS
18. Dossiers were forwarded to the SSA, a phone call was received in April, advising that
the analyst is working on the matter and a response will be arriving in 2 weeks. It was not
received yet.
19. Addressed the issue with Justice Scalia on March 9th.
20. Addressed the issue with Chief Justice Roberts on March 13th.
21. 15 trips were made to lobby elected and appointed officials in different states to review
the issue of Obama’s eligibility for presidency
22. Over a 100 radio shows and numerous TV shows, documentaries and newspaper and
magazine articles were done to bring awareness to the issue of lack of eligibility of
Obama for the presidency of the US.
23. During the meeting with the KY assistant secretary of state a letter was written by the
assistant secretary of state to the Attorney General of the state, requesting to verify
Obama’s eligibility
24. 4 TN state representatives joined the legal action to unseal Obama’s eligibility
25. 3 MO state representatives joined the legal action

26. 2 NH state representatives joined the legal action
27. Over a 100 members of the US military including high ranked officials such as major
General joined the action
28. A request for Quo warranto investigation was made, on behalf of the WY Guardsman
Matthew Michael Edwards upon the Governor and attorney general of WY.
29. Meetings were conducted with 9 state representatives and state senators in the State of
WA, as well as WA assistant Atty Gen. and WA FBI
30. FBI field offices were visited in a number of states.
31. A meeting was conducted with the National director of the selective service William
Chatfield.
32. Case presentation was done to a number of citizen’s common law grand juries, which
indicted Barack Hussein Obama with fraud and in some states treason.
33. Meetings with volunteers were conducted in San Antonio, TX during April 15 tea party.
34. Pleadings and dossiers were hand delivered to the office of the Governor of GA Sonny
Purdue, Atty Gen of GA, elections committee and US Atty Nahmias. First citizen’s grand
jury was organized by the foreman Mr. Carl Swenssen.
35. Meetings were conducted with the speaker of the House of OK Chric Benge, state
senator and current candidate for Gov of OK Randy Brangdon, st. rep Dr. Mike Ritz.
36. Met with current leading candidate for governor of Al Judge Moore and one of Al
electors Robert Cusanelli became one of the plaintiffs.
[1] Lisa Liberi remains under the continuing jurisdiction of the Superior Court of the State of California for the
County of San Bernardino in connection with her probation or parole status in Case No: FSB-044914 (Judge John
M. Pachecho), and whether this is determinative of her citizenship for diversity purposes or not, it seems more than
casually significant that Judge John M. Pacheco, in allowing Lisa Liberi to post bail bonds and be released from
custody stated on the record, in open court on August 4, 2004:
“Having said all that, Ms. Liberi, if you don’t come back here [“here” meaning to California Superior Court
whenever required by the terms of her probation] the mud is going to be on my face that I allowed all this to
happen.” Defendant Lisa Liberi responded “I will be here, your Honor. I have made every court appearance.” The
issue concerning the citizenship of parolees and probationers is not well-settled, but would seem to favor “last
residence prior to sentencing” as the residence of the probationer/parolee, which in this case would definitely be
California.
Under the diversity jurisdiction statute, the federal courts have original jurisdiction to decide a plaintiff’s state-
law lawsuit if the dispute “is between . . . citizens of different States.” See 28 U.S.C. § 1332(a)(1). A party’s
“citizenship” for purposes of federal jurisdiction is determined by looking to the person’s domicile. See Crowley v.
Glaze, 710 F.2d 676, 678 (10th Cir. 1983). Domicile, in turn, is determined by finding the last place where a person
resided with an intention of remaining there indefinitely. See Mississippi Band of Choctaw Indians v. Holyfield, 490
U.S. 30, 48, 104 L. Ed. 2d 29, 109 S. Ct. 1597 (1989) (”For adults, domicile is established by physical presence in a
place in connection with a certain state of mind concerning one’s intent to remain there.”); Crowley, 710 F.2d at 678
(”To effect a change in domicile, two things are indispensable: First residence in a new domicile, and second, the
intention to remain there indefinitely.”).
It is obviously true that an adult can freely and intentionally change her residence for purposes of diversity
jurisdiction as a matter of fundamental right, but prisoners, probationers, and parolees ordinarily lose the right to
determine their own citizenship. Lisa Liberi does not have complete freedom to sever her ties to California, and in
fact she has promised NOT to do so, as shown in the above quoted lines from the Reporter’s Transcript of the
August 4, 2004, hearing in San Bernardino Superior Court Case No.: FSB-44914. page 122, to which this Defendant
Some courts have recognized that the restrictions on the liberty of a prisoner affect the determination of the
prisoner’s domicile because domicile is a voluntary status. See Sullivan v. Freeman, 944 F.2d 334, 337 (7th Cir.
1991). As a result, courts have applied a presumption that when a prisoner has been moved out-of-state by prison
officers, the prisoner’s citizenship for diversity purposes is the state where he was domiciled before he was
imprisoned. See id.; see also Ferrer v. Dailey, 1996 U.S. App. LEXIS 33322, No. 96-3155, 1996 WL 731618, at *1
(10th Cir. Dec. 20, 1996) (unpublished Order & Judgment) (”For purposes of diversity jurisdiction, when an
inmate has been forcibly incarcerated in another state, the state of citizenship ’should be the state of which he was
a citizen before he was sent to prison unless he plans to live elsewhere when he gets out, in which event it should be
that state.‘”) (quoting Singletary v. Continental Ill. Nat’l Bank & Trust Co., 9 F.3d 1236, 1238 (7th Cir. 1993)). This
presumption, however, is rebuttable upon a showing of sufficient facts to indicate that a prisoner has both residence
and present intent to remain indefinitely in a new state. See Sullivan, 944 F.2d at 337.
Posted in Uncategorized | 12 Comments »

EXHIBIT “20”

2009
« Previous Post
Ties to Everett, need help with research

,
You mentioned Everett, Wash. connection with Barack Obama’s mother’s family. Just
wondering if you knew that connection went back for over a century…
http://www.heraldnet.com/apps/pbcs.dll/article?AID=/20081026/NEWS01/710269867
Plus a bit more about the Wolfleys: http://www.santacruzsentinel.com/world/ci_12517525
So with a POTUS with a Muslim father and German roots mother, why shouldn’t Israelis be
worried?
If you do post this info, please don’t mention my name or email.
Cheers
Response
I am really concerned about several coincidences
1. a man who threatened to shoot me and burn my body for the world to see was tracked to a
computer server in Everett WA. Another person that threatened me was traced to Chauhelis WA
and yet another one to Canada (from what I understand not far from the border with WA state).
A few days after the threat there was a clamp missing and a disconnected fumes emissions hose
in my car and my husbands car died, suddenly a fuse was missing.
2. Obama does not talk about it, but his mother wasn’t in HI when he was a baby, she was
enrolled in the U of Seattle WA from August 1961-till June 1962, which means that as a baby he
lived in WA.
3. Lisa Liberi, assistant for Berg, who has a lengthy criminal record of grand theft, forgery
of documents and forgery of official seal doesn’t talk about it, but according to records she
was born in WA state. From what I recall Bellview WA. (her name at birth was Lisa
Richardson. From what I recall father -Jack Richardson, mother Shirley Wadell)
4. Obama, Liberi and Obama’s mother Stanley Ann Dunham- all have multiple social
security numbers according to databases.
5. Liberi was convicted of forgery of documents and according to experts, there are
multiple signs of forgery in Obama’s documents.
6. Stanley Ann Dunham also went by the name Shirley Ann Dunham.
We found a Dunham organization, owned by Shirley Ann Dunham; one location was in
Seattle another in Bellview WA. They dealt with insurances, lawyers, mortgages- you can
get ss numbers from all of these records.
7. From what I recall, there was a discrepancy between Intellius records and Secretary of state
records. According to the sec. of state a man owned that co. One of our volunteers pulled court
records in Bellview for the Dunham organization. This man, Mr. Dunham (don’t remember first
name) kept changing his middle initial in several court cases, which was suspicious by itself.
8. There was a very strange newspaper article in WA (I believe Seattle), from what I recall, when
Obama supposedly was in Columbia. It stated that one, Roman Obama studied at the university
of Patrice Lumumba in Moscow, Russia, and had some financial difficulties.
9. When grandma Dunham got sick, a reporter from WA (I believe Seattle) has writen an
interview with Charles Payne, saying the grandma got a broken hip. She was dead of cancer a
few days later. I was wondering, why did it come out in WA, and not HI or IL?
10. Based on all of the above, I have a nagging feeling, that there is somebody there in WA,
some relative of Obama, somebody who we might think is no longer with us.
This entry was posted on Monday, June 22nd, 2009 at 3:35 pm and is filed under Uncategorized. You can follow
any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.
[emphasis added]
EXHIBIT “21”

2009
« Update MI
I am back from PA. Very Important. »
Unfortunately I have to spend more time on Berg’s latest motion, I

have to provide a response

Orly Taitz Law Offices
(949) 683-5411
dr_taitz@yahoo.com
UNITED STATES DISTRCT COURT

Lisa Liberi, et al., §

Plaintiffs, §
§
v. § Civil Action No. 2:09-cv-01898-ER
§
Orly Taitz, et al. §
Defendants §
DEFENDANT’S OPPOSITION TO EMERGENCY MOTION FOR THE ISSUANCE OF

PLAINTIFFS’ INJUNCTION OR RESTRAINING ORDER
.
Defendants Orly Taitz and Defend Our Freedoms Foundation hereby file their opposition
and objections to Plaintiffs’ motion for injunctions for following reasons:
1. The First Amendment provides that “Congress shall make no law… abridging the
freedom… of the press,” and it is “no longer open to doubt that the liberty of the press, and of
speech, is within the liberty safeguarded by the due process clause of the Fourteenth Amendment
from invasion by state action.” Near v. Minnesota ex rel. Olson, 283 U.S. 697, 707 (1931). See
also Grosjean v. American Press Co., 297 U.S. 233, 244 (1936). The United States Supreme
Court has interpreted these guarantees to afford special protection against orders that prohibit the
publication or broadcast of particular information or commentary - orders that impose a
“previous” or “prior” restraint on speech. None of the Supreme Court’s decided cases on prior
restraint involved restrictive orders entered to protect a convicted forger’s history of convictions
for forgery, but the opinions on prior restraint have a common thread relevant to this case.
2. “Prior restraints on speech and publication are the most serious and the least tolerable
infringement on First Amendment rights.” Pittsburgh Press Co. v. Pittsburgh Comm’n on
Human Relations, 413 U.S. 376, 390, 37 L.Ed. 2d 669, 93 S.Ct. 2553 (1973): a prior restraint
should not “sweep” any “more broadly than necessary”. As such, the Constitution forbids prior
restraint on freedom of publication in the press, media, all together. See Carroll v. President and
Comm’rs of Princess Anne, 393 U.S. 175, 183-184, 21 L.Ed.2d 325, 89 S.Ct. 347 (1968).
3. Any “order” issued in “the area of First Amendment rights” must be “precise” and
narrowly “tailored” to achieve the “pin-pointed objective” of the “needs of the case”. Tory v.
Cochran, 544 U.S. 734, 738 125 S. Ct. 2108, 2111; 161 L.Ed.2d 1042, 1048 (2005); see
also Board of Airport Comm’rs of Los Angeles v. Jews for Jesus, Inc., 482 U.S. 569, 575, 577,
96 L.Ed.2d 500, 107 S.Ct. 2568 (1987) (regulation prohibiting “all ‘First Amendment activities’”
substantially overbroad).
4. The Plaintiffs’ June 23, 2009, proposed order in this case is laughably unspecific and
substantially overbroad, and would basically impose a “Plaintiffs’ standard” censorship on
Defendants’ commentary on the world-wide web, with the Court enrolled as enforcing referee.
5. Nearly two months have passed since the filing of Plaintiffs’ complaint, and both the title
and substance of Philip J. Berg’s latest “ex-parte” motion confirm, demonstrate, and reaffirm that
there are no recently developing emergencies or exigent circumstances which compel action at
the present time, if any action were ever warranted at all (cf., e.g., Tory v. Cochran, 544 U.S.
734 (supra).
6. Plaintiffs’ requests for injunctions when aligned and evaluated against their somewhat
lame and insubstantial recitations of alleged past misconduct are non-sensical, because Plaintiffs
Liberi, Berg, et al. make no allegations and offer no evidence of any ongoing defamation or
publication of private facts, and in particular, none that have arisen since the initiation of their
present Suit to Limit Access to Public Proceedings (e.g. “SLAPP”) filed May 4, 2009.
7. Historically, defamatory speech and disclosure of private facts of adults are immunized
from legislative or executive censorship, as well as judicial injunctive relief (known as “prior
restraint”) in the United States. If false statements are made, which result in injury, damages are
the sole and exclusive remedy.
8. All of the substantive requests, including but not limited to the key phrase in the proposed
order submitted to this Court on June 23, 2009, “Defendants’ Orly Taitz … Defend our
Freedoms Foundation… [….and] …all parties acting on their behalf are enjoined from
airing and/or publishing any defamatory or false statements”, and 100% of Defendants’
request for injunctive relief concerns expressive activity, specifically Defendants’ activities as
purveyors of truthful information through the electronic media communications over the “world-
wide web” or “internet.”

9. As the United States Supreme Court articulated 33 years ago this month (June 30, 1976)
in Nebraska Press Association v. Stuart, 427 U.S. 539; 96 S.Ct. 2791; 49 L.Ed.2d 683, 697-98
(1976):
A prior restraint, by contrast and by definition, has an immediate and irreversible

sanction. If it can be said that a threat of criminal or civil sanctions after
publication “chills” speech, prior restraint “freezes” it at least for the time. … The
damage can be particularly great when the prior restraint falls upon the
communication of news and commentary on current events. Truthful reports of
public judicial proceedings[1] have been afforded special protection against
subsequent punishment. See Cox Broadcasting Corp v. Cohn, 420 U.S. 469, 492-
493 (1975); see also, Craig v. Harney, 331 U.S. 367, 374 (1947). For the same
reasons the protection against prior restraint should have particular force as
applied to reporting of criminal proceedings, whether the crime in question is a
single isolated act or a pattern of criminal conduct.
10. In that same case (Nebraska v. Stuart) the Supreme Court set out an analytical and
procedural test for prior restraint on expressive activities which has been widely followed
throughout the United States. Under this test, a prior restraint on expression is presumptively
unconstitutional. With this concept in mind, the court adopts the following test: a [injunctive]
order in civil judicial proceedings will withstand constitutional scrutiny only where there are
specific findings supported by evidence that (1) an imminent and irreparable harm to the judicial
process will deprive litigants of a just resolution of their dispute, and (2) the judicial action
represents the least restrictive means to prevent that harm. See, for example, the Texas Supreme
Court’s Analysis in Davenport v. Garcia, 834 S.W.2d 4, 10 (1992).
11. Defendants suggest that this Court specifically adopt the Texas four part rendition of the
Nebraska v. Stuart test, in that several of the Defendants in this case are in fact from Texas and
would be entitled to such protection if they had been sued “at home”:
Concerned that public prejudice could prevent impanelling of a jury, a trial judge
issued an order restraining the news media from publishing any information about
a murder suspect in Nebraska Press Ass’n v. Stuart, 427 U.S. at 542-43. The
United States Supreme Court invalidated the order as an unconstitutional prior
restraint, noting that: (1) the underlying basis was too speculative; (2) less
restrictive alternatives were not investigated; (3) no evidence was presented that
the prior restraint would have in fact achieved its purpose; and (4) the order was
overbroad. Id. at 562-69. These conclusions are quite fact specific, id. at 569, and
thus only serve to reinforce a presumption that prior restraints, including those
directed at media publication, are unconstitutional.
Davenport v. Garcia, supra, at 10.
12. “A responsible press has always been regarded as the handmaiden of effective judicial
administration, especially in the criminal field. Its function in this regard is documented by an
impressive record of service over several centuries. The press does not simply publish
information about trials but guards against the miscarriage of justice by subjecting the police,
prosecutors, and judicial processes to extensive public scrutiny and criticism.” Sheppard v.
Maxwell, 384 U.S. 333 at 350 (1966).
13. Censorship of the press was, quite simply, one of the primary and central evils brought
over the water from monarchical and ecclesiastical domination in Europe against which the First
Amendment was enacted and adopted by Congress and the original 13 states. As the Court
recited in its historical summary in Nebraska Press Ass’n v. Stuart, supra: in Patterson v.
Colorado ex rel. Attorney General, 205 U.S. 454, 462 (1907): “[T]he main purpose of [the First
Amendment] is ‘to prevent all such previous restraints upon publications as had been practiced
by other governments.’” Defendant Dr. Orly Taitz was born in a country, the Soviet Union, in
which restraints on freedom of expression were ubiquitous and constituted a constant feature of
everyday life.
14. All content-based prior restraints on the dissemination of information by and through the
free media or “press” by judicial injunction constitute a form of “censorship” of free expression
which are subject to strict scrutiny and a very important series of safeguards outlined by the
Supreme Court for this central, core of First Amendment Protections. Lisa Liberi and Philip
Berg completely and callously ignore, in their memorandum, the fact that the entire thrust of the
injunctive relief they seek is focused on the suppression of freedom of speech and
communication about a topic of general public interest in the free press and open media. They
do not cite in their memorandum of law a single First Amendment case nor any other authority
which would show them entitled to any relief of any kind whatsoever.
15. All of the pleadings filed by the plaintiffs in this case were done with the sole reason to
harass Defendant Dr. Orly Taitz and other defendants and try to keep them silent about the fact
that Berg’s assistant Liberi has a criminal record, specifically criminal record of forgery of
documents, which casts doubt on documents Berg has submitted to this honorable court as well
the Supreme court, as the documents were prepared or at least handled by a convicted document
forger. This is a matter of public concern and public interest as well as a legitimate topic of press
reporting and is entitled to full First Amendment protection.
16. Lisa Liberi has (in California Courts) demonstrated a pattern of filing frivolous legal
actions and motions, having filed groundless actions against police officers, district attorney, the
judge and the county solely to obtain leverage in her own criminal actions, or for other improper
purposes.
17. Philip J. Berg has shown the same pattern of filing frivolous and fraudulent actions and
was fined by US District Judge J. Curtis Joyner more then $10,000 for bringing legal actions
“utterly barren of any scintilla of legal principles”. In his opinion Judge Joyner has stated “This
court has grown weary of Mr. Berg’s continuous disregard and brazen disrespect toward this
court and his own clients. Mr. Berg’s actions …are an enormous waste of judicial time and
resources that this court cannot, in good conscience, allow to go unpunished”. In this action Berg
has filed hundreds of pages of pleadings without a scintilla of proof or legal theory upon which
he can possibly proceed against the defendants.
18. This opposition to motion for emergency injunction and or restraining order is filed with
full reservation of rights, as the defendants are awaiting the ruling on their second amended
motion to dismiss due to lack of jurisdiction.
19. Due to the fact that not one but several serious questions concerning the existing either of
Federal Question or Diversity jurisdiction over this case, Defendants reserve their right to plead
further in opposition to Plaintiffs’ request for “emergency injunctive relief” if this Court should
decide it does indeed possess jurisdiction.
20. However, the question of the Court’s power to proceed does and should indeed precedes
any other issues of litigation and due to the fact that the defendants were harassed by hundreds
and hundreds of pages of pleadings and premature demands for discovery, even though the
defendants are waiting for the ruling on jurisdiction, the defendants respectfully request a stay on
all other proceedings and filing of subsequent motions and pleadings until there is a ruling on
jurisdiction.
Respectfully submited
Wednesday, June 24, 2009

By:________________________________
Defendant, in propia persona and on behalf
of Defend Our Freedoms Foundations, Inc..
Dr. Orly Taitz, President,
Telephone (949) 683-5411

E-Mail: dr_taitz@yahoo.com
[1] Such as Defendant Orly Taitz’ reports on the CLOSED (not ongoing) legal proceedings
involving Lisa Liberi.
This entry was posted on Wednesday, June 24th, 2009 at 12:19 am and is filed under Uncategorized. You can follow
EXHIBIT “22”

2009
« Unfortunately I have to spend more time on Berg’s latest motion, I have to provide a response
Next Post »
I am back from PA. Very Important.

I appreciate everybody calling and e-mailing and texting to make sure I am OK. I am OK….I
had to go to PA to appear at the hearing in the garbage law suit filed by Philip Berg. My wireless
connection didn’t work there, I couldn’t blog.
I returned yesterday at 12:30 and and was doing a radio show in VA with Chuck Chrismayer.
You can reach him at 800-754-1822 or 804-677-2783, he will have archives of the show.
I had to work from 1-5:30 and later wanted to have dinner and spend some time with my family.
In regards to Berg things are going well. Judge denied all of his motions for default judgment
against me and clerical default was lifted, he gave me a pro hac vice to represent my foundation,
denied all of Berg’s motions for injunction against me and, what is most important he ordered
Berg to show cause, why his case should not be dismissed due to lack of jurisdiction. For those
of you, who are not attorneys, it is a very good sign that the judge is very inclined to dismiss
Berg’s case due to lack of jurisdiction. I would like to explain that if the case is filed out of state,
the first thing that is being reviewed, is jurisdiction. It doesn’t mean that the case has any merit
aside from jurisdiction, it means that this court cannot hear it. I believe Berg filed it in PA to
simply cause me to waste time and money, going to Philly. At any rate, I am not concerned about
this frivolous law suit, I am though concerned about something else.
On the plane to Philly I read hundreds of pages of transcripts in criminal case hearings of Liberi.
Keep in mind that recently I had threats “to shoot me and burn my body for the world to see”.
Later a clamp was missing and fumes emissions hose was disconnected in my car, that lead to
the fumes accumulating around the engine, which is extremely dangerous.
As I read August 4, 2004 transcript, I found a testimony of detective Liebreich. He testified in

regards to recording of phone calls Lisa Liberi made from jail to her husband Brent Liberi. She
was telling him that she was upset with her sister Cheryl Richardson. Cheryl cooperated with the
police and told them about 19 prior criminal investigations of Liberi. Liberi told Brent (see
copies of the transcripts attached) that she will get her sister in jail and will spread the word that
she is a rat. She was telling Brent “do you know what they do in prison to rats?”
At that time DA James Secord asked the detective to explain. The detective stated that a contract
will be issued on such person, a green light and such person will be attacked and/ or killed. He
mentioned that 5 people were killed last year alone. I got concerned, if this woman could plan
a hit, a contract on her own sister, it would not be inconceivable that she would plan a hit on an
attorney and her family, if this attorney outed her. I kept reading and found out that indeed less
then a year later her sister was dead. Official cause of death, from what I understand, is drug
overdose. However, drug overdose can be self inflicted or inflicted by others.
At this time I would like to know if there are any pathologists among the readers of this blog?
Can someone go to the police department and probation department in Santa Fe NM and show
them all this info.
According to detective Teresa Standiford from Orange County economic crimes unit, my report
and the whole file was transferred to Santa Fe, as Lisa Liberi lives there. I tried to find out the
status, but it is very hard to reach anybody in the police department there. The phone number of
detective Teresa Standford in CA 714-647-7486, 714-647-7038. Case # 09-068339.
Liberi’s prosecuting DA in Ca is James Secord 909-387-8309
In Santa Fe I was given a number for detective Martin Lopez 505-955-5010, General number for
the Santa Fe police is 505-955-5038. Investigations unit- 505-955-5038
The supervisor of her probation department is Joan Martinez 505-476-2359 Regional probation
officer is Rose Bobchack 505-476-2363.
After the hearing on Thursday I talked to Phil Berg and I have shown him the transcripts of
Liberi’s prior hearings. I put him on notice in regards to her dangerous propensities and let him
know that if he continues with this law suits and continues denying, what is clearly a public
record, he endangers me and my whole family. If something happens and Liberi is involved, he
will be held accountable as an accomplice.
This entry was posted on Saturday, June 27th, 2009 at 3:52 pm and is filed under Events, Uncategorized. You
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LIBERI V TAITZ - EXHIBITS 1-22 TO Show Cause Response

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LIBERI V TAITZ - EXHIBITS 1-22 TO Show Cause Response

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Case 2:09-cv-01898-ER Document 106-2 Filed 08/26/2009 Page 1 of 7

Dr. Orly Taitz Esquire

« Dr. Orly Taitz Esquire

Dr. Orly Taitz, ESQ

Attorney General Eric Holder;

Via Certified mail, return receipt, restricted delivery addressee only

Dossier #6 in the form of

engaged in a complex fraud involving falsification of police reports, manipulation of credit

a. Obama’s Natural Born status and definition of it

Dr. Orly Taitz, ESQ

NOTE: EXHIBIT “A” REDACTED DUE TO LENGTH OF DOCUMENT

> From: nsankey@thesankeyfirm.com

From: Neil SANKEY <nsankey@thesankeyfirm.com>

From: Neil SANKEY [mailto:nsankey@thesankeyfirm.com]

Call, if you need to, at your convenience.

THE SANKEY FIRM

Simi Valley, California 93063

805 520 3151

LISA RENEE LIBERI. Bn 5/28/1965. 462-45-xxxx, 622-19-4312 (& others)

From: Neil SANKEY <nsankey@thesankeyfirm.com>

This report came from volunteer Sarah redacted

NOTE: ATTACHED PRINT-OUT WAS REDACTED DUE TO LENGTH

Dr. Orly Taitz Esquire

Follow up on Lisa Liberi, paralegal to Phil Berg

Dr. Orly Taitz Esquire

« Key witness in presidential passport case fatally shot

Every day I get such evidence of missing or misdirected funds

Dear Joseph Iadarola,

Confirmation number: 0MT49606HT922673B

Donations coordinator: Defend Our Freedoms

Dr. Orly Taitz Esquire

« Supporting Documents, Downloads.

Update on Lisa Ostella and Lisa Liberi

Dear Dr. Taitz;

Dr. Orly Taitz Esquire

« Updates on radio shows; Interview at 6:30 PM PDT on No Compromise Radio

More attacks on me. More indepth research is done in spite of attacks

I am preparing dossier #7 and I need help in research in the following areas:

2. any info on campaign contributions from Baxter to Obama

4. who are the major shareholders of Baxter?

Dr. Orly Taitz Esquire

« Proposed quo warranto, to be delivered to Atty. Gen of GA

Check public records for yourselves, see that I am providing truthful

6. I wonder in regards to timing of this complaint, as I am making progress in a number of states

Dr. Orly Taitz Esq.

Follow up on the FBI

More on Lisa Liberi, contact her probation officer in Santa Fe

Dr. Orly Taitz Esquire

I need two articles and update on Lisa Liberi

Dr. Orly Taitz Esquire

« from another attorneys

Information update on both Liberi and Obama

His last postings on his site:

01/02/09: BERG files a lawsuit on behalf of a RETIRED COLONEL The lawsuit is an

Dr. Orly Taitz Esquire

Update on Obama investigation and Liberi investigation

Case Number Results In Same

Case FSB044914 Defendant 1608112 LIBERI, LISA

PC OFFER/ETC FALSE/FORGED INSTRUMENT

PC OFFER/ETC FALSE/FORGED INSTRUMENT

PC OFFER/ETC FALSE/FORGED INSTRUMENT

Name Search Results

DUPLICATES AND FEDERAL EXPRESS PICTURES REDACTED